When Can an ERISA Claimant Get Discovery Beyond the Administrative Record? Court Allows Targeted Conflict-of-Interest Discovery in Long COVID Disability Case

In Mason v. New York Life Insurance Company, No. 1:26-cv-01429 (DEH) (SDA), 2026 WL 2445531 (S.D.N.Y. Aug. 20, 2026), United States Magistrate Judge Stewart D. Aaron resolved a discovery dispute in an ERISA long-term disability action, granting the claimant limited discovery beyond the administrative record while denying other requests. The decision offers a practical illustration of how courts in the Second Circuit decide what an ERISA claimant can obtain outside the record when a structural conflict of interest is in play.

What was the ERISA dispute about?

Plaintiff worked as a Senior Desktop Engineer for the American Jewish Committee and participated in an employee benefit plan that provided long-term disability benefits. He was diagnosed with long COVID in October 2025 and filed a claim for benefits in November 2025, asserting total disability. New York Life Group Insurance Company of NY, the plan administrator, denied the claim in February 2026, finding Plaintiff ineligible for any benefits under the Plan. Plaintiff filed suit, alleging the denial violated the Plan and ERISA. The Plan is fully insured by the administrator, meaning the same entity both evaluates and pays claims. (Note that the court did not rule on whether the denial was wrongful; the dispute before it concerned only discovery.)

Can an ERISA claimant obtain discovery outside the administrative record?

Generally, when reviewing an ERISA claim denial under either the arbitrary-and-capricious or de novo standard, district courts limit their review to the administrative record before the plan at the time of the denial. A court may consider evidence outside the record only upon a showing of good cause. One recognized example of good cause is a record that is demonstrably incomplete. To obtain discovery, however, the claimant need not make a full good cause showing. Applying the majority rule in the Circuit, the court explained that the claimant must instead show a “reasonable chance” that the requested discovery will satisfy the good cause requirement, supported by specific factual allegations rather than generic requests.

What discovery did the court allow regarding the completeness of the record?

Plaintiff sought discovery to test whether the administrative record was complete, pointing to a “feedback” report allegedly missing from the record, review “checklists,” and documents that were allegedly deleted from the record. The court permitted Plaintiff to serve targeted interrogatories under Rule 33 and targeted document requests under Rule 34 limited to those three items. The court denied Plaintiff’s request for a Rule 30(b)(6) deposition on completeness, finding it not proportional to the needs of the case. A separate request to identify which entity employed three named individuals was resolved when Defendants disclosed the employer in their briefing, and Plaintiff’s request for internal rules and procedures was withdrawn after Defendants produced certain documents.

How did the conflict of interest affect the discovery analysis?

A plan administrator operates under a structural conflict of interest when it both evaluates claims and pays benefits, and Defendants conceded that this conflict existed here. A structural conflict alone does not constitute good cause to go outside the record, but it can rise to that level when bolstered by specific allegations. The court’s rulings on the conflict-related requests split along the line of how directly each category connected to the decision-makers on Plaintiff’s own claim. The standard of review remained unresolved, and Plaintiff conceded that if the case were reviewed de novo, he would not require any conflict-of-interest discovery; the conflict would matter only under a deferential standard.

What conflict-of-interest discovery did the court deny?

Plaintiff sought information about the Defendants’ two in-house file reviewers, Dr. Yvette Yeung and Dr. Fidelis Mkparu, including the number of file reviews they conducted, a sample of twenty reports they prepared before and after Plaintiff’s, and how often they found claimants able or unable to return to work. The court denied these requests, reasoning that bare numbers or percentages of claim denials are meaningless without additional context, and that context cannot be supplied without holding mini-trials on other claims. As an independent ground, the court found this category not proportional to the needs of the case.

What conflict-of-interest discovery did the court allow?

The court granted two categories tied directly to the individuals who administered Plaintiff’s claim. First, it ordered Defendants to produce documents showing the bases for, and the existence of, any financial incentives provided to the two file reviewers and two other named employees for 2025 and 2026, reasoning that compensation tied to the frequency of claim denials could pose a risk of arbitrary action relevant to Plaintiff’s claim. Second, the court ordered Defendants to produce performance evaluations for those same four employees for 2025 and 2026, reasoning that whether an employee’s performance is measured by reference to the ability to deny or terminate claims bears directly on whether the conflict biased the decision-making process.

What happens next in the case?

The court set a case schedule: Defendants and Plaintiff must complete the ordered discovery within 14 days, any motion to amend or join parties is due by September 3, 2026, fact discovery closes November 30, 2026, and any motion for leave to take expert discovery is due by December 14, 2026. The ruling resolves only the scope of discovery; the merits of the benefit denial remain to be decided.