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S.D. Ohio- Plaintiff's entitlement to discovery regarding Conflict of Interest

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  • S.D. Ohio- Plaintiff's entitlement to discovery regarding Conflict of Interest

    In a recent case from the Southern District of Ohio, the court explores in what circumstances a plaintiff is entitled to discovery against an insurance company. In this case, Plaintiff alleged:
    [Minnesota Life] labored under a conflict of interest in that it simultaneously occupied the roles of drafting plan terms, interpreting those terms to its advantage, deciding all benefit claims and funding the plan, such that its decision to deny accidental death benefits arising from the death of Mr. McVay inured to its financial advantage. In so acting to decide the McVay benefit claim in face of these conflicts of interest, [Minnesota Life] breached fiduciary duties owed to plan beneficiaries, including Mr. McVay and by representation, Plaintiffs.
    The court, borrowing logic from Johnson v. Connecticut Gen. Life Ins. Co., outlined three "concrete" rules to be used in the analysis of these claims:
    (1) plaintiffs seeking procedural or conflict-of-interest discovery must do more than merely allege bias; (2) plaintiffs are not required to meet any evidentiary-threshold showing to obtain such discovery; and, (3) plaintiffs are not automatically entitled to such discovery.
    Ultimately, the court held that Plaintiff's allegations went beyond the threshold of mere allegation of bias, conflict of interest, or procedural defect. Accordingly, the court found that Plaintiff is entitled to limited discovery regarding Metropolitan Life's conflict of interest and/or Met Life's physician's possible conflict of interest. The full opinion is attached below.
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