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Opportunity to Conduct Discovery for a converted Rule 56 Motion: W.D. Wash.

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  • Opportunity to Conduct Discovery for a converted Rule 56 Motion: W.D. Wash.

    In a recent case out of Washington, the court converts a 12(b)(6) motion to a Rule 56, and continues the motion for 90 days to allow the parties to conduct discovery. The Plaintiff alleges that: "(1) the Welfare Plan and the Disability Plan “cannot be the complete Plan documents,” as neither includes the Plan’s definition of disability that was cited in the letter denying her disability benefits and her appeal; (2) the Disability Plan – the only document by which the Committee purports to delegate fiduciary duties to Sedgwick – is merely a summary plan description, and is not an “enforceable part” of the plan or a “source of the plan’s governing terms”; and (3) the Welfare Plan refers to “Insurance Contracts” between the Plan Administrator and Sedgwick – “perhaps including such salient details as the Plan Administrator’s formal delegation of its fiduciary duties and the applicable definition of ‘disability’” – but no such document is provided."

    The court was persuaded by the Plaintiff's contentions and found:

    While the Plan documents suggest that the Committee in fact delegated its authority to determine disability claims and appeals to Sedgwick and may properly be dismissed (see Anderson v. Sun Life Assur. of Canada, Inc., 647 Fed. App’x 772, 774 (9th Cir. 2016), vacated on other grounds, 652 Fed. App’x 527 (9th Cir. 2016)), there remains an unresolved dispute as to the authenticity and completeness of these documents. Accordingly, the Court cannot properly rule on the motion to dismiss without first converting it into a Rule 56 motion for summary judgment. See Fed. R. Civ. P. 12(d) (“If, on a motion under Rule 12(b)(6) or 12(c), matters outside the pleadings are presented to and not excluded by the court, the motion must be treated as one for summary judgment under Rule 56. All parties must be given a reasonable opportunity to present all the material that is pertinent to the motion.”).
    As such, the court afforded the parties time to conduct discovery in order to present material relevant to the motion. The full opinion is attached below.
    Attached Files