Benson v. Hartford Life & Accident Insurance
District Court, D. Utah · 2010-07-21
This ERISA case arose after Hartford Life and Accident Insurance Company terminated a premium waiver on Janice Benson's life insurance policy, determining she no longer qualified as disabled under the plan, which led to denial of benefits upon her death; her husband sued to recover the benefits. The parties disagreed during scheduling on whether any discovery should occur beyond the administrative record. The court granted the plaintiff's request for limited discovery focused on potential conflicts of interest between Hartford and the third-party medical reviewers (UDC) and between Hartford and the employer. The reasoning centered on the Supreme Court's MetLife v. Glenn decision, which requires courts to consider conflicts of interest in reviewing benefit denials, and distinguished this request from cases where discovery was denied because it targeted bias evidence rather than new medical information, drawing support from Tenth Circuit precedent and similar cases allowing such inquiry.
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