Crosby v. Louisiana Health Service and Indem. Co.
647 F.3d 258
5th Cir.2011Background
- Crosby was insured under the Blue$aver HDHP Plan (ERISA-governed).
- The Plan denied coverage for periodontal procedures to prevent tooth loss; Crosby appealed internally and the denial was upheld.
- Crosby sued under ERISA §1132(a)(1)(B) and the district court granted summary judgment for Blue Cross on the administrative record theory.
- Crosby sought discovery beyond the administrative record; the magistrate and district court limited discovery.
- The Fifth Circuit vacated and remanded for broader discovery, holding Vega governs admissible evidence scope but discovery may extend beyond the administrative record for procedural and related issues.
- The court cautioned district courts to guard against abusive discovery and remanded for appropriate discovery.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Scope of admissible evidence and discovery in ERISA benefits actions | Crosby seeks evidence beyond the administrative record to show procedural failures and completeness of record. | Blue Cross relies on Vega to limit evidence to interpretive or medical terms within the record. | Remand for further discovery; broader scope acknowledged. |
| Whether the magistrate abused discretion by limiting discovery | Limitation prejudiced Crosby's ability to show procedural noncompliance and record incompleteness. | Discovery should be narrowly tailored to admissible evidence. | Abuse of discretion; vacate judgment and remand for discovery. |
Key Cases Cited
- Vega v. National Life Insurance Services, Inc., 188 F.3d 287 (5th Cir.1999) (limits evidence to administrative-record-related matters unless helpful to past interpretations or medical terms)
- Estate of Bratton v. National Union Fire Insurance Co., 215 F.3d 516 (5th Cir.2000) (evidence outside the administrative record may be relevant to completeness)
- Murphy v. Deloitte & Touche Group Ins. Plan, 619 F.3d 1151 (10th Cir.2010) (applies Rule 26(b) discovery in ERISA actions; broad but controlled scope)
- Metro. Life Ins. Co. v. Glenn, 554 U.S. 105 (2008) (defines conflict of interest as a factor in abuse-of-discretion review)
- Doe v. Blue Cross & Blue Shield United of Wis., 112 F.3d 869 (7th Cir.1997) (ERISA review akin to administrative-review process; limits on discovery)