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ERISA Discovery Limited to Evidence before Administrator in Deferential Review Case

ERISA Discovery Limited to Evidence before Administrator in Deferential Review Case

Blake v. Union Camp Int'l Paper, 622 F. App'x 853 (11th Cir. 2015)


ERISA and Life Insurance News
(April, 2016)

Blake brought an action to recover pension benefits alleged to be due under an ERISA plan. In the district court, Blake sought to compel discovery of documents beyond those contained in the administrative record. The district court denied the motion to compel and granted summary judgment to the plan administrator.

The Eleventh Circuit affirmed the decision on appeal. "A district court reviewing a denial of ERISA benefits where, as here, the plan administrator is granted broad discretionary authority, applies an arbitrary and capricious standard of review," the court wrote. 

"In such a review, the district court should limit discovery to the evidence that was before the plan administrator when it denied the claim for benefits," the court continued. "The district court is limited to 'the facts as known to the administrator at the time the decision was made,'" the court concluded,  quoting Glazer v. Reliance Standard Life Ins. Co., 524 F.3d 1241 (11th Cir. 2008). 

Blake could not show that the district court abused its discretion in refusing to allow additional discovery. Rather, "the court properly limited discovery to the evidence that the ERISA plan administrator had before it in making its decision regarding Mr. Blake's benefits." Indeed, "[n]othing else that Mr. Blake could have discovered was relevant," the court reasoned.

Click here to view the full April 2016 Edition of the ERISA and Life Insurance News.

Authors
H. Sanders Carter
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Andrea K. Cataland
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Kenton J. Coppage
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Dorothy H. Cornwell
T (404) 962-1096
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Mary B. Ramsay
T (843) 300-6659
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