Court Partially Grants Discovery in ERISA Disability Case Against Hartford Life

In Gannon, MD v. Hartford Life and Accident Ins. Co., No. 3:24-CV-01955 (VAB), 2025 WL 2886648 (D. Conn. Oct. 3, 2025), the District of Connecticut addressed how far claimants can go in seeking discovery beyond the administrative record in an ERISA long-term disability benefits case. The ruling offers important guidance for both attorneys litigating ERISA claims and individuals navigating insurer denials.

Background: Limited Discovery Under ERISA

Under ERISA, courts reviewing benefit denials generally limit their analysis to the administrative record—the documents and evidence before the insurer when it made its decision. However, courts may allow additional discovery if the plaintiff shows “good cause.” This case turned on what that standard means in practice.

Dr. Gannon, a physician whose disability benefits were denied by Hartford Life, sought discovery on two grounds:

1. Procedural irregularities in how Hartford handled her claim; and
2. A conflict of interest stemming from Hartford’s dual role as both claims administrator and payor.

The Court’s Decision: Discovery Allowed in Part

Judge Victor A. Bolden granted discovery related to alleged procedural irregularities but denied it regarding Hartford’s alleged conflict of interest.

1. Procedural Irregularities

The court held that several of Dr. Gannon’s requests fit squarely within her rights under the ERISA Claims Procedure regulation, 29 C.F.R. § 2560.503-1. That regulation entitles claimants to all documents “relevant to” a benefit determination — including those relied upon, considered, or generated during the claim process.

Because Hartford was required to produce these materials even outside of litigation, the court allowed Dr. Gannon’s discovery requests. These included interrogatories, deposition topics, and document requests aimed at determining whether Hartford followed proper claims procedures.

2. Conflict of Interest

However, the court denied discovery on Hartford’s potential financial bias. Simply pointing to Hartford’s role as both decision-maker and insurer was not enough to show good cause. The court emphasized that plaintiffs must show “additional facts beyond the existence of the conflict” — such as inconsistent review procedures, improper incentives, or relationships suggesting bias.

Dr. Gannon’s reliance on Hartford’s denial letter, which included standard language asserting impartiality, did not meet this threshold.

Key Takeaways for ERISA Practitioners

• Procedural Discovery Can Be Granted: Courts may compel insurers to produce documents required under ERISA’s own procedural rules. Attorneys should frame discovery requests explicitly within 29 C.F.R. § 2560.503-1.
• Conflict Discovery Remains Narrow: Plaintiffs must present evidence suggesting the insurer’s conflict actually affected the claim decision.
• Strategic Framing Matters: Plaintiffs who tie discovery requests directly to regulatory entitlements, rather than broad fairness concerns, are more likely to succeed.

Why This Matters for Claimants

For individuals denied disability benefits, this ruling underscores the importance of the administrative record. The evidence you provide during your insurer’s review often defines the limits of what a court can later consider. This is why it is important to seek legal advice before preparing your own appeal.