District of Idaho Denies Leave to Add New York Life as Defendant in ERISA Disability Case, Finding Proposed Amended Complaint Fails to Plausibly Allege Control Over Benefits Determination

In Gadberry v. Life Insurance Company of North America, No. 2:25-cv-00391-BLW, 2026 WL 765698 (D. Idaho Mar. 18, 2026), the District of Idaho granted in part and denied without prejudice in part a plaintiff’s motion to amend his complaint in an ERISA long-term disability case. The court allowed him to add his employer and related plan entities as defendants but refused to permit the addition of New York Life Insurance Company, finding that the proposed amended complaint failed to plausibly allege that New York Life exercised control over the administration of his claim.

Plaintiff Nathan Gadberry suffers from single-sided deafness with an auditory processing disorder. He received long-term disability benefits under a group disability policy issued by Life Insurance Company of North America (LINA), but LINA later terminated his benefits and denied his administrative appeal. Gadberry originally sued LINA in July 2025, seeking past and future benefits, costs, interest, and attorneys’ fees under ERISA § 502(a)(1)(B). He subsequently moved to amend his complaint to add three new claims — including equitable relief under § 502(a)(3) — and to name four new defendants: New York Life Insurance Company (which he alleged was also known as New York Life Group Benefit Solutions, or NYLGBS); his employer, Science Applications International Corporation (SAIC); SAIC’s Benefits Committee; and SAIC’s Health and Welfare Benefits Plan. LINA did not oppose the addition of the employer-related entities or the new claims, but opposed adding New York Life.

The court applied the standard governing leave to amend under Federal Rule of Civil Procedure 15(a)(2), which directs that courts should freely grant leave when justice so requires, subject to considerations of bad faith, undue delay, prejudice, futility, and prior amendments. For futility purposes, the court examined whether the proposed amended complaint could survive a motion to dismiss under Rule 12(b)(6).

On the § 502(a)(1)(B) claim against New York Life, the court applied what it described as the “restrained functionalist” approach that courts of appeals have coalesced around, under which a plaintiff may sue an entity other than the formally designated plan administrator if that entity exercises actual control over plan administration or the benefits determination at issue. The court found that Gadberry’s proposed amended complaint fell well short of that standard. The only allegation specifically addressing New York Life’s role stated “upon information and belief” that New York Life and LINA together “controlled” the disability policy, accompanied by a general reference to correspondence bearing NYLGBS letterhead. The court found these allegations conclusory. It also noted that the complaint obscured each defendant’s individual role by repeatedly attributing conduct to “Defendants” collectively while using singular pronouns — an internal inconsistency that was particularly problematic given that the original complaint had specifically attributed all relevant conduct to LINA alone.

The court distinguished Gadberry’s complaint from the complaint in Chevalier v. BAE Systems, Inc., 2025 WL 870342 (D.D.C. Mar. 20, 2025), which survived dismissal on similar facts because the plaintiff there included specific, detailed factual allegations about New York Life’s role — that New York Life denied her claims, received and evaluated her appeals, and sent denial letters. The court in Chevalier described those allegations as “factual assertions about events in the real world,” not legal conclusions, and they supported a reasonable inference of actual control. Gadberry’s complaint offered only bare recitals that did not cross the plausibility threshold.

The court reached the same conclusion on the § 502(a)(3) claim, finding no factual allegations from which to infer that New York Life exercised the discretionary authority or control over plan management necessary to establish fiduciary status under 29 U.S.C. § 1002(21)(A).

The court denied the motion to add New York Life without prejudice. It noted that correspondence Gadberry submitted for the first time on reply — including letters on NYLGBS letterhead stating “We are reviewing” his LTD claim and “We are your employer’s Long Term Disability insurer,” along with an email from a New York Life consultant — could potentially support his theory, but he had not incorporated those materials into the proposed amended complaint. The court also observed that submitting the correspondence on reply left LINA with no opportunity to respond. The court gave Gadberry 60 days to file a revised amended complaint and suggested he consider conducting limited discovery into the corporate structure and entity status of NYLGBS before deciding whether to pursue claims against New York Life.