District Court Allows Discovery Beyond Administrative Record in ERISA Case over Disputed Employment Termination

In Est. of Green v. Hartford Life & Accident Ins. Co., No. 24-CV-1910-ABA, 2025 WL 834068 (D. Md. Mar. 17, 2025), the United States District Court for the District of Maryland addressed the denial of an accidental death insurance claim under an ERISA-governed plan administered by Hartford Life and Accident Insurance Company (Hartford). Sidney Green, an employee of Piedmont Airlines, died in a motorcycle accident on June 1, 2019. He was covered under a group accidental death and dismemberment (AD&D) policy provided by Piedmont and administered by Hartford. Hartford denied the claim, relying on a statement from Piedmont that Green’s employment had been terminated on May 22, 2019, a week before his death. The plaintiff, the Estate of Sidney Green, contested this termination, citing communications with the union and other evidence suggesting Green was still employed. The Estate challenged Hartford’s decision to deny the benefit, arguing that Mr. Green was still employed at the time of his death, contrary to Hartford’s determination. In this decision, the court granted the Estate’s motion to compel Piedmont to produce documents that the Estate subpoenaed, including documents about whether Mr. Green remained employed as of the date of his death, and the circumstances of his alleged termination.

The court focused on whether Hartford abused its discretion in denying the claim, which required an analysis of the adequacy of the materials Hartford considered and whether the decision-making process was reasoned and principled. Under the Fourth Circuit’s Booth factors for abuse-of-discretion review, the court considered the language of the plan, the purposes and goals of the plan, and the adequacy of the materials considered by Hartford, among other factors.

The court noted that discovery in ERISA cases is generally limited to the administrative record but acknowledged that limited extrinsic discovery is permissible to assess the adequacy of the materials considered by the plan administrator. The Estate sought additional discovery from Piedmont, arguing that the administrative record was incomplete and inadequate to support Hartford’s denial of the claim. Specifically, the Estate sought documents related to Piedmont’s termination procedures under the collective bargaining agreement (CBA) and whether the union was notified of Green’s alleged termination, as required by the CBA.

The court granted the Estate’s motion to compel discovery from Piedmont, emphasizing the relevance of the requested information to determine if Green was indeed terminated in accordance with the CBA’s requirements. The court found that the information was necessary to assess the adequacy of Hartford’s decision-making process and whether it was consistent with the procedural and substantive requirements of ERISA.

The court ordered Piedmont to produce documents regarding its termination policies and any communications regarding Green’s employment status. This decision underscores the court’s willingness to allow limited discovery outside the administrative record in ERISA cases where the completeness and adequacy of the record are questioned, particularly when the plan’s terms are intertwined with external agreements like a CBA.