Newman v. Standard Ins. Co.

7 Citing cases

  1. MAYNARD v. CNA GROUP LIFE ASSURANCE COMPANY

    No. CIV 04-0525 PHX RCB (D. Ariz. Jan. 10, 2006)

    In abuse of discretion cases, evidence outside the administrative record is completely inadmissible. Newman v. Standard Insurance Company, 997 F.Supp. 1276, 1280 (C.D. Cal. 1998). "Permitting a district court to examine evidence outside the administrative record would open the door to the anomalous conclusion that a plan administrator abused its discretion by failing to consider evidence not before it."

  2. Alford v. DCH Foundation Group Long-Term Life Ins. Co. of America

    144 F. Supp. 2d 1183 (C.D. Cal. 2001)   Cited 7 times
    Stating that plaintiff failed to produce any evidence that "self-interest, or conflict of interest, on UNUM's part affected its decision-making or otherwise led to a breach of fiduciary obligations" -e.g., "[t]here is no allegation or evidence that UNUM has offered inconsistent bases for denial, changed its interpretation of plan documents, failed to follow internal procedures for making claims or appealing denials, or otherwise allowed a conflict of interest to taint its decision"

    If the plan does not meet its burden, courts review the decision to deny benefits de novo.Friedrich, 181 F.3d at 1109 (citing Atwood, 45 F.3d at 1323); see also Newman v. Standard Ins. Co., 997 F. Supp. 1276, 1279 (C.D.Cal. 1998). "Only if the administrator does meet its burden is it entitled to the deferential abuse of discretion standard of review."

  3. Aluisi v. Elliott Manufacturing Co., Inc. Plan

    CV F 04-5373 AWI SMS (E.D. Cal. Jun. 15, 2006)

    The court recognizes that some courts have refused to grant any discovery requests in ERISA actions. In Newman v. Standard Insurance Co., 997 F.Supp. 1276 (C.D.Cal. 1998), the Central District of California held that there is no entitlement to discovery on the plan's possible conflict of interest because such discovery might be so extensive that it would undermine one of the primary goals of ERISA — to resolve disputeS over benefits inexpensively and expeditiously. Id. at 1280-81.

  4. Klund v. High Technology Solutions, Inc.

    417 F. Supp. 2d 1155 (S.D. Cal. 2005)   Cited 14 times
    Denying discovery requests as overbroad and not relevant whether the decision making process was affected by dual role as insurer and administrator

    Indeed, as Plaintiff argues, the consequence of interpreting Tremain to endow a beneficiary with the ability to present evidence of conflict of interest, without allowing that beneficiary to conduct discovery on those issues would amount to granting the beneficiary a right without an effective remedy. Defendants correctly cite Newman v. Standard Insurance Co., 997 F.Supp. 1276, 1280-81 (C.D.Cal. 1998) in support of their position with regard to discovery. Id. (holding that there is no entitlement to discovery on the apparent conflict between an insurance company's role as administrator and funding source of a benefits plan because such discovery might be so extensive that it would undermine one of the primary goals of ERISA — to resolve disputes over benefits inexpensively and expeditiously). Nevertheless, the only effective way for an ERISA plaintiff to enforce the right to present evidence of conflict of interest is to preserve his or her ability to discover such evidence.

  5. Stanley v. Metropolitan Life Insurance Company

    312 F. Supp. 2d 786 (E.D. Va. 2004)   Cited 14 times
    Noting that "the Fourth Circuit precludes discovery of non-record information, and therefore prohibits courts probing into the recesses of the administrator's mind"

    To allow discovery in every ERISA case involving an administrator who is also the funding source "would involve far-reaching, open-ended, nearly limitless discovery." Newman v. Standard Ins. Co.. 997 F. Supp. 1276,1280 (C.D. Cal. 1998). The tremendous expenses thereby incurred would frustrate the prompt and affordable resolution of benefit claims. Plaintiff cites several Ninth Circuit cases for the proposition that the court is not limited to the administrative record when determining whether an actual conflict of interest has tainted the benefit decision.

  6. Fought v. Unum Life Ins. Co. of America

    CIV No. 01-124 PK/LFG (ACE) (D.N.M. Feb. 6, 2002)   Cited 1 times

    Several district courts have examined this same question and have declined to allow discovery (when applying an arbitrary and capricious standard of review). In Newman v. Standard Ins. Co., 997 F. Supp. 1276, 1280 (C.D.Cal. 1998), the trial court recognized that the plaintiff did not seek discovery on the merits of the claim, but wanted discovery as to the issue of whether the conflict tainted the administrators decision. The plaintiff, in Newman, argued that the only way to obtain material, probative evidence beyond the mere fact of the apparent conflict was through discovery.

  7. Stills v. GBMC Healthcare, Inc.

    48 F. Supp. 2d 495 (D. Md. 1999)   Cited 6 times
    Upholding denial of benefits, where administrator's consultant determined that no objective information had been provided to support disability claim

    " Thus, the plain language of the plan confers discretionary authority on Standard to determine benefits eligibility. See Snow v. Standard Ins. Co., 87 F.3d 327, 330 (9th Cir. 1996) (plan granting authority to determine eligibility for benefits inherently confers discretion); Newman v. Standard Ins. Co., 997 F. Supp. 1276, 1278 (C.D.Cal. 1998) (interpreting identical language as providing Standard with discretionary authority). Accordingly, I will review Standard's decision to deny Ms. Stills's short-term disability claim under an abuse of discretion standard.