When Must an ERISA Life Insurance Plan Show How It Treats Similar Claims? A Texas Court Lets a Widow’s Claims Proceed

In Richards v. LifePoint Health Welfare Benefits Plan, No. 3:25-CV-3541-X, 2026 WL 3391457 (N.D. Tex. Nov. 6, 2026), the United States District Court for the Northern District of Texas considered whether an ERISA life insurance plan must give a beneficiary the information she needs to show that the plan treated similarly situated claimants differently. The court held that the plan’s failure to produce that information allowed two of her claims to survive dismissal, while it dismissed a third claim with prejudice.

What happened to the life insurance claim?

Plaintiff’s husband began full-time employment with LifePoint and elected life insurance coverage on November 25, 2024. On December 26, 2024, he collapsed, went to a hospital, and never returned to work. He died on February 2, 2025. Lincoln National Life Insurance Company issued the policy, which required an employee to complete an Eligibility Waiting Period that ended on the first of the month following 30 days of continuous, active employment. Lincoln read the policy to require the employee to stay in active employment through the waiting period and any remaining days until coverage began on January 1, 2025. Because the insured did not work from December 26 to January 1, Lincoln treated him as ineligible and denied Plaintiff’s claim. The court had already dismissed Plaintiff’s first complaint without prejudice, holding that Lincoln’s interpretation sat at least on the low end of reasonableness and allowing Plaintiff to amend to allege that LifePoint treated similarly situated claimants differently.

Why did the court let Plaintiff’s ERISA claims proceed?

Plaintiff’s amended complaint relied on hypothetical comparators, and the court observed that actual decisions, not hypothetical ones, are what matter. The court nonetheless denied dismissal of Plaintiff’s first two counts because LifePoint failed to give her information that 29 C.F.R. § 2560.503-1 required it to disclose. That regulation entitles a claimant, upon request and free of charge, to all documents, records, and other information relevant to the claim, which includes information demonstrating that the plan applied its provisions consistently to similarly situated claimants. The court reasoned that it had permitted Plaintiff to amend to allege differential treatment, yet she could not meet that requirement because LifePoint refused to share any information about how it assesses similar claims by others it insures. Because LifePoint deprived Plaintiff of information the court had required her to plead and the law entitled her to receive, the court denied the motion as to her first and second counts.

Does Texas or Tennessee law govern the policy’s discretionary clause?

Plaintiff separately argued that Texas law, which bars discretionary clauses in life insurance policies, should apply and displace abuse-of-discretion review. The court rejected that argument. The Plan stated that it would be construed under ERISA and, absent another identified state, the law of Tennessee, and the Plan incorporated the policy as a Component Plan. Because the administrator relied on the document containing the Tennessee choice-of-law provision, the court held that Tennessee law governs, that Tennessee does not prohibit discretionary clauses, and that abuse-of-discretion review therefore applies. The court dismissed Plaintiff’s claim under Texas Insurance Code § 1701.062 with prejudice.

The court granted the motion in part and denied it in part. Plaintiff’s first and second counts may proceed, and the court limited discovery to whether LifePoint treats similarly situated individuals differently when it denies life insurance claims.