Byrd v. Metropolitan Life Insurance Company

2008 WL 974787, Not Reported in F.Supp. 2d (2008)

This memo and order, regarding a pre-trial discovery dispute, was important because the District Court listed the relevant regulations and caselaw that would control the determination of an ERISA benefits claim.  We called the court’s attention to the regulations at 29 C.F.R. § 2560.503, which define the relevant documents that must be provided to a claimant.  Byrd v. Metropolitan Life Ins. Co., 2008 WL 974787 at *1.  Further, we called the court’s attention to Palmiotti v. Metropolitan Life Ins. Co., 2006 WL 510387 (S.D.N.Y. Mar.1, 2006) that required Metlife to produce its “Best Practices Manual,” the predecessor to the current Claims Management Guidelines.  Id.

MetLife argued that the regulations relied on by the Plaintiff did not make the guidelines generally discoverable, citing Bradford v. Metropolitan Life Ins. Co., No. 3:05-cv-240 (E.D. Tenn. Apr. 18, 2006)(holding ERISA regulations do not require production of the entire Claims Management Guidelines, but only “the guidelines that were actually consulted and used in connection with adjudicating plaintiff’s claims”).  Id.  Although the court held here that the Bradford case controlled and that only the Claims Management Guidelines that were actually consulted and used in the adjudication of Plaintiff’s claim would be discoverable, the court left the door open for a different decision when the Guidelines would be used in the claims adjudication process.  Id. at 2.