1. Case Name: Schoolman v. United Healthcare Ins. Co., United States District Court for the Eastern District of Missouri, Eastern Division, December 18, 2013
- Counsel for Plaintiff: Matthew R. Davis, Heller and Gallagher, LLP
- Counsel for Defendant:
- Brian R. Shank, Evans and Dixon
- Brian W. Thompson, Donald T. Campbell, Leonard and Street
3. Format: Published Memorandum and Order.
4. Outline: Plaintiff brings this individual action against Defendant insurer. Plaintiff is a 25-year-old resident of New York and was a covered dependent under her father’s employer-sponsored group health plan. Plaintiff suffers from an eating disorder and was admitted to a treatment center for treatment; Defendant denied Plaintiff’s preauthorization for this service as it was deemed not medically necessary. Plaintiff appealed and was denied. After completing residential treatment, Plaintiff sought authorization to continue treatment in an Intensive Day Program. This was also denied as not medically necessary.
Defendant had previously brought a Motion to Dismiss Count III based on Plaintiff’s failure to state a claim. The Court granted that Motion.
5. Legal Pointer: Here, the Plaintiff seeks limited discovery and production of documents and a deposition of Defendant’s corporate representative to determine if there is a conflict of interest and procedural irregularities in Defendant’s claims review process. The Defendant argues against the Motion for limited discovery stating that the Court’s review is limited to the record that was before the plan administrator.
6. Legal Issues and Causes of Action: In her claim, Plaintiff argues that the administrative record is not sufficient and that she has good cause to conduct limited discovery to determine if there is a conflict of interest between Oxford and UBH. Plaintiff argues that since both companies are part of the same umbrella company, United Healthcare, the limited discovery is warranted.
- Ruling: The Court grants Plaintiff’s Motion for Limited Discovery but denies to grant the request for a deposition of Defendant’s designated representative.
7. Narrative Case Description: The Plaintiff, a covered dependent, brings suit against the Defendant insurer for damages when the Defendant denied claims for her inpatient and outpatient therapy for an eating disorder. Plaintiff alleges violations of the New York and Missouri parity laws, claiming that the plan did not provide mental health coverage that is comparable to health benefits under the plan. Defendant successfully applied for a Motion to Dismiss Count III, arguing a lack of factual basis for the claim.
The motion before the Court for limited discovery is based upon Plaintiff’s argument that the administrative record lacks any documentation about the potential conflict of interest between UBH and Oxford relating to the claims process. Plaintiff argues that the Court should permit to her to conduct discovery to determine if the insurance company’s experts and doctors were independent. The Court agrees with Plaintiff’s argument and grants Plaintiff’s Motion.
8. Additional Comments: None
9. Website: http://www.leagle.com/decision/In%20FDCO%2020131219A67/SCHOOLMAN%20v.%20UNITED%20HEALTCARE%20INSURANCE%20COMPANY
10. Practical Implications and Lessons Learned: Although Plaintiff cannot conduct discovery relating to the application of New York state mental health parity laws, the Court does allow discovery to determine if there is a conflict of interest in the claims process.
11. All Legal Theories Presented in Case: Judicial review in ERISA cases
12. Successful Legal Theories in Case: Judicial review in ERISA cases