Utah Federal Court Grants Partial Discovery in Accidental Death Benefits Dispute, Requires Supplementation of Administrative Record

In Mayor v. Metropolitan Life Insurance Company, No. 1:25-cv-00012, 2026 WL 1339911 (D. Utah May 14, 2026), a Utah federal magistrate judge granted in part and denied in part a claimant’s motion for discovery and sustained in part the claimant’s objection to the completeness of the administrative record in an ERISA accidental death benefits case.

What was this case about?

Plaintiff’s husband, a Union Pacific employee, died in May 2023. His death was attributed to fentanyl, and MetLife, the claim administrator, denied accidental death benefits on the basis of a policy exclusion for deaths caused by the “voluntary” use of illicit drugs. Plaintiff asserted two ERISA claims: one for improper denial of benefits, and one for statutory damages based on alleged failure to provide required plan information. After the administrative record was filed, Plaintiff objected to its completeness and sought discovery across seventeen document requests grouped into four categories: (i) MetLife’s inherent conflict of interest as claim administrator and claim payor (requests 4, 5, and 14 through 17); (ii) documents not in the record that should have been, including the actual ERISA plan, documents granting MetLife discretionary authority, and documents establishing MetLife’s failure to consider whether the drug ingestion was “voluntary” under Utah law (requests 1 through 3 and 6 through 12); (iii) documents the defendants referenced in their pleadings (requests 1 through 11); and (iv) documents relating to MetLife’s role in responding to requests for plan information (request 13).

What did the court say about discovery into MetLife’s dual-role conflict of interest?

The court denied discovery into MetLife’s conflict of interest as both claim administrator and claim payor. Through requests 4 and 5, Plaintiff sought all documents creating, revising, or defining MetLife’s status as claim administrator and claim payor. Request 14 sought all documents describing MetLife’s policies, procedures, manuals, and guidelines for handling claims in its dual role, including any impact on deciders’ compensation or performance evaluations. Request 15 sought all communications between the defendants describing how MetLife should handle claims in its dual role. Request 16 sought documents reflecting how MetLife recognized and addressed its conflict with respect to Plaintiff’s specific claim. Request 17 sought documents reflecting the financial reserves for the claim, the impact of claims payment, and the identity of persons who knew the reserves.

Drawing on Murphy v. Deloitte & Touche Group Insurance Plan, 619 F.3d 1151 (10th Cir. 2010), the court identified three factors courts must consider in evaluating such requests: whether ERISA’s goal of fair and informed resolution is served, whether the efficiency goals of ERISA are served, and whether the discovery is necessary given its benefits, burdens, and costs. The court found that Plaintiff failed to address or apply any of these factors, and offered nothing beyond the bare fact of MetLife’s dual role to justify the requests. While MetLife acknowledged its dual role, the court explained that acknowledgment alone does not make broad extra-record discovery appropriate. The court denied requests 4, 5, and 14 through 17 on this basis.

Did the court require supplementation of the administrative record to include plan documents?

In part. Plaintiff argued the record was incomplete because it contained only a summary plan description rather than a separate “master plan document.” The court rejected that framing, finding no authority requiring that a plan’s written instrument take the form of a master plan document, and noting that Tenth Circuit precedent permits provisions contained only in a summary plan description to be enforceable. However, the court granted the motion to the extent it sought all plan documents MetLife actually compiled in the course of denying the claim, consistent with 29 C.F.R. § 2560.503-1(m)(8)(ii). The defendants were directed to either supplement the record with any missing documents or provide a verified statement confirming the record is complete.

What happened with the request for documents establishing discretionary authority?

The court granted discovery on this point. Plaintiff argued that nothing in the record clearly demonstrated Union Pacific granted MetLife discretionary authority to decide her claim, and that judicial review should be de novo absent such evidence. The defendants pointed to two provisions in the summary plan description they contended conferred that authority. The court found the defendants’ reliance on those provisions overstated their clarity: the first said nothing specifically about MetLife, and the second used language suggesting the grant of authority “has been” delegated, implying the existence of other memorializing documents. Because the applicable standard of review had not yet been determined, the court allowed discovery limited to documents whereby Union Pacific granted MetLife discretion over accidental death benefits claims.

Did the court allow discovery to establish that MetLife failed to consider Utah law?

No. Request 7 sought all documents regarding MetLife’s determination of the proper choice of law, including all documents regarding the applicability of Utah law as raised by Plaintiff in her appeal, and documents reflecting how MetLife recognized and addressed Plaintiff’s argument that her husband’s drug ingestion was not “voluntary” under Utah law. Plaintiff argued that MetLife ignored legal authority she submitted on appeal defining “voluntary” drug ingestion under Utah law as requiring actual knowledge of the substance ingested, and contended discovery was necessary to establish that MetLife failed to consider this argument. The court denied the request, reasoning that if the record itself showed MetLife abused its discretion by ignoring the submitted authority, no additional discovery was needed. The record was sufficient on its face.

What did the court order regarding a document MetLife relied on in its briefing?

The court ordered MetLife to add to the administrative record an “Application for Group Insurance” that it had attached as an exhibit to its response brief but which was not in the record. MetLife used this document to argue that Nebraska law governed the benefits claim. The court found that MetLife’s reliance on the document in its briefing indicated it had considered or should have considered it during the benefits determination, and ordered it included in the record.

Was discovery permitted on the statutory damages claim?

Yes. Plaintiff sought agreements between Union Pacific and MetLife relating to MetLife’s role in responding to plan information requests, arguing that MetLife acted as Union Pacific’s agent in carrying out its statutory disclosure obligations. The court granted discovery on this request, holding that the general restriction on extra-record discovery in ERISA cases applies to evidence of a claimant’s eligibility for benefits, not to claims that fall outside that scope. An agency relationship between Union Pacific and MetLife, if established, could be the basis for imputing MetLife’s disclosure failures to the plan administrators. The court found these agreements, if they exist, are necessary to the statutory damages claim, relevant outside the benefits determination context, and would aid in fair and efficient resolution on the merits.

The court directed defendants to supplement the administrative record or provide verified statements by June 11, 2026, or a mutually agreed date.