District Court Denies Insurer’s Attempt to Block Discovery in ERISA Benefits Case

In Gaines v. United of Omaha Life Insurance Company, No. 1:25-CV-00167-HAB-ALT, 2025 WL 2675105 (N.D. Ind. Sept. 18, 2025), Magistrate Judge Andrew Teel rejected an insurer’s effort to vacate the scheduling order and foreclose discovery in an ERISA disability benefits case. The court held that United of Omaha’s motion was, in substance, an improper request for reconsideration and amounted to nothing more than a rehashing of previously rejected arguments.

Background

United of Omaha filed a “motion to vacate” the court’s scheduling order permitting discovery, contending that discovery is neither warranted nor appropriate in ERISA litigation. Plaintiff Gaines opposed, arguing discovery was necessary to address potential conflicts of interest and patterns in claim administration. United of Omaha alternatively requested a protective order under Federal Rule of Civil Procedure 26(c).

Court’s Analysis

1. Motion to Vacate Construed as Motion to Reconsider

The court treated United’s motion as one for reconsideration under Rule 54(b). See Terry v. Spencer, 888 F.3d 890, 892 (7th Cir. 2018); Galvan v. Norberg, 678 F.3d 581, 587 (7th Cir. 2012). Citing Caisse Nationale de Credit Agricole v. CBI Indus., Inc., 90 F.3d 1264, 1269 (7th Cir. 1996), and Bank of Waunakee v. Rochester Cheese Sales, Inc., 906 F.2d 1185, 1191 (7th Cir. 1990), the court emphasized that reconsideration is disfavored and appropriate only to correct manifest errors of law or fact or to present newly discovered evidence.

Here, United’s arguments failed to demonstrate any misunderstanding, error, or change in controlling law. Instead, the motion merely recycled prior contentions against discovery, which is insufficient. See BioConvergence LLC v. Attariwala, No. 1:19-cv-01745, 2023 WL 3570043, at *1 (S.D. Ind. May 19, 2023).

2. Discretion to Allow Discovery in ERISA Cases

The court underscored that district courts retain discretion to permit discovery in ERISA benefits litigation, particularly where issues of disability or entitlement to benefits are at stake. See Ehas v. Life Ins. Co. of N. Am., No. 12 C 3537, 2012 WL 5989215, at *10 (N.D. Ill. Nov. 29, 2012). United’s insistence that discovery conflicted with ERISA’s “administrative purposes” was unpersuasive.

3. Protective Order Denied

United’s alternative request for a protective order also failed. The motion did not identify specific discovery requests warranting restriction but instead made generalized complaints about conflict-of-interest discovery and requests for statistical data. The court noted that perfunctory arguments do not merit detailed consideration. See Williams v. Dieball, 724 F.3d 957, 963 (7th Cir. 2013). As a result, the motion for a protective order was denied without prejudice. Plaintiff’s embedded request for protective relief was also denied for procedural defects under N.D. Ind. L.R. 7-1(a).

Conclusion

The court denied United of Omaha’s motion to vacate with prejudice, denied its alternative motion for a protective order without prejudice, and denied plaintiff’s procedurally improper protective order request. The decision reaffirms that:

1. Reconsideration is an extraordinary remedy, not a vehicle to reargue issues already decided.
2. District courts maintain discretion to allow discovery in ERISA cases, particularly where issues of bias or fairness may be explored.
3. Insurers opposing discovery must identify specific burdens or improper requests; generalized objections are inadequate.