What Counts as Your ERISA Plan Document? A Utah Court Limits Discovery and Defines the Record

In Mayor v. Metropolitan Life Insurance Company, No. 1:25-cv-00012-DBB-DAO, 2026 WL 1815564 (D. Utah June 24, 2026), United States District Judge David Barlow overruled Plaintiff’s objection to a magistrate judge’s order that granted in part and denied in part her motion for additional discovery in an ERISA benefits dispute. The decision walks through several recurring fights over the scope of ERISA discovery and the contents of the administrative record, and it resolves each one against Plaintiff.

The case arises under ERISA and concerns benefits under the Union Pacific Corporation Nonagreement Life Insurance Plan, insured and administered by MetLife. After MetLife filed the administrative record, Plaintiff moved for additional discovery on four fronts: MetLife’s conflict of interest as both claims payor and claims administrator, additional plan documents including a claimed “Master Plan Document,” MetLife’s consideration of whether the decedent’s ingestion of fentanyl was “voluntary” under Utah law, and MetLife’s authorization to respond to records requests. The magistrate judge granted the motion in part and denied it in part, and Plaintiff objected.

What standard of review applies to a magistrate judge’s discovery order in an ERISA case?

Clear error, not de novo. Plaintiff argued the court should review the magistrate judge’s order de novo under Rule 72(b)(3). Judge Barlow rejected that position. Rule 72(a) governs review of nondispositive matters and permits the court to set aside only orders that are “clearly erroneous or contrary to law.” Rule 72(b) requires de novo review only for dispositive motions. Because the order addressed discovery disputes and the completeness of the administrative record, it was nondispositive, and the court applied the clear error standard throughout.

Must an ERISA plan administrator produce a separate “Master Plan Document”?

Not on this record. Plaintiff’s central objection was that the magistrate judge refused to order production of a separate master plan document, arguing that ERISA’s text requires both a written plan instrument under 29 U.S.C. § 1102(a)(1) and a summary plan description under § 1022(a), so the two must be distinct documents. She relied on CIGNA Corp. v. Amara for the proposition that summary documents do not themselves constitute the terms of the plan. The court explained that the Tenth Circuit narrowed Amara in Holmes v. Colorado Coalition for the Homeless Long Term Disability Plan, which held that provisions of a summary plan description remain enforceable when they do not conflict with the plan or when they expressly state that they are part of the plan. Under that precedent, the summary plan description could operate as the governing ERISA plan document alongside the insurance policy, as MetLife argued. The court found no clear error in the magistrate judge’s conclusion that Plaintiff failed to identify any specific plan document actually missing from the record, particularly because the magistrate judge had already ordered MetLife to supplement the record with any additional plan documents compiled in denying the claim or to provide a verified statement that the record is complete.

Can the court add a document to the administrative record over the claimant’s objection?

Yes. Plaintiff objected that the magistrate judge improperly required MetLife to supplement the record with an “Application for Group Insurance.” The magistrate judge had reasoned that the application formed part of the contract and was apparently relied upon by MetLife in determining which state’s law applied. Plaintiff argued the application postdated the relevant policy and lacked authentication under oath. The court rejected both points. The application was dated September 1, 2020, the operative policy became effective January 1, 2023, so the application preceded the relevant policy and could have informed MetLife’s decision. Plaintiff also offered no authority that each document in an ERISA administrative record must be authenticated under oath. The court found no clear error.

Does a court err by crediting one party’s arguments over the other’s?

No. Plaintiff argued the magistrate judge treated MetLife’s attorney assertions as fact. The court explained that a judge may reference a party’s arguments and may find one party’s arguments more credible than the other’s. Plaintiff also contended that the magistrate judge wrongly confined certain discovery requests to her conflict-of-interest theory when they also bore on MetLife’s delegated authority, discretion under the plan, and role as a Union Pacific agent. The court noted that the magistrate judge had independently considered each category of requested discovery, and that a magistrate judge facing an overly broad request may address the principal arguments rather than every potential application of the requested documents.

Disposition

The court overruled Plaintiff’s objection in full and left the magistrate judge’s order in place.