Utah Federal Court Allows Limited Discovery into MetLife’s Conflict of Interest in AD&D Denial

In Kramer v. Metropolitan Life Insurance Company, No. 2:25-cv-00327, 2025 WL 3171499 (D. Utah Nov. 13, 2025), the U.S. District Court for the District of Utah granted plaintiffs’ request for limited discovery into MetLife’s conflict of interest based on its dual role as both claims administrator and payor of benefits. The decision provides a helpful reminder that, in ERISA cases involving conflicting medical opinions and evolving rationales, courts may permit targeted discovery to assess whether the insurer’s structural conflict influenced its claim decision.

Background

The decedent participated in Wells Fargo’s employee welfare benefit plan, which included life insurance and accidental death and dismemberment (“AD&D”) coverage issued and administered by MetLife. After the decedent passed away in 2021, MetLife paid basic life insurance benefits but denied two AD&D claims—one for $600,000 and another for $75,000—based on a policy exclusion for death caused by drugs not taken as prescribed.

Plaintiffs appealed, offering evidence that the decedent had been prescribed oxycodone “as needed.” MetLife obtained an external peer review from Dr. Michael Darracq, who asserted for the first time that the decedent had taken venlafaxine at toxic levels. Plaintiffs countered with their own toxicologist, Dr. Patricia Williams, who disputed those conclusions. MetLife nevertheless upheld its denials.

Plaintiffs then filed suit and moved for limited discovery targeted at MetLife’s conflict of interest, including its use of peer reviewers, compensation structures, training materials, and internal claims-handling procedures.

Legal Standard for Extra-Record Discovery in ERISA Cases

Although ERISA cases are typically confined to the administrative record, courts may allow discovery beyond the record when the insurer operates under a structural conflict of interest—i.e., when it both determines eligibility for benefits and pays claims from its own funds. Citing Glenn, Murphy, and related Tenth Circuit authority, the court reiterated that plaintiffs must show that extra-record discovery is appropriate and proportional under Rule 26.

The Court’s Analysis

The court agreed that limited discovery was warranted. Several factors supported this conclusion:

• Conflicting medical opinions raised during the administrative process.
• MetLife’s introduction of new rationales during the peer-review stage.
• Questions about internal procedures, the use of outside reviewers, and potential financial incentives.

The court emphasized that the existence of a dual-role conflict is not, by itself, a “green light” for discovery. However, plaintiffs had identified specific issues suggesting that MetLife’s conflict may have influenced its decisionmaking.

Discovery Requests Allowed

The court permitted discovery on the following topics:

• Identification of individuals involved in claim evaluation and appeal.
• Compensation, bonuses, and performance evaluations for those individuals.
• The resumes/CVs of medical reviewers.
• MetLife’s guidelines, training materials, and claims-handling procedures for AD&D claims, including policies on peer review.
• Data regarding MetLife’s relationship with the specific physicians and companies used to conduct reviews in this case.

These requests were found to be relevant, proportional, and narrowly tailored to determining whether MetLife’s conflict impacted its decisions.

Discovery Requests Rejected

Other requests were deemed overbroad, including:

• Company-wide hiring, firing, and compensation data.
• Regulatory investigations over the past ten years.
• All complaints involving AD&D denials.
• Broad financial reports and statistical data.
• An interrogatory seeking information about MetLife’s use of a peer-review vendor without any time limitation.

The court found these requests disproportionate to the needs of the case and outside the scope permitted under Rule 26.

Takeaway

This decision underscores that, even in circuits that generally restrict ERISA discovery, courts will permit targeted inquiry into an insurer’s conflict of interest when the record contains red flags, such as:

• shifting or newly-raised rationales for denial,
• competing expert opinions, and
• unanswered questions about how peer reviewers are selected or compensated.

For claimants facing denials by insurers that both administer and pay claims, this ruling reaffirms the importance of identifying concrete reasons why discovery is needed to evaluate the impact of the insurer’s structural conflict.