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Sugiyama v. Unum Life Insurance Company of America

United States District Court, N.D. California

April 17, 2017

MYRA SUGIYAMA, Plaintiff,
v.
UNUM LIFE INSURANCE COMPANY OF AMERICA, et al., Defendants.

          ORDER DENYING PLAINTIFF'S MOTION TO LIMIT SCOPE OF THE ADMINISTRATIVE RECORD Re: Dkt. No. 31

          PHYLLIS J. HAMILTON United States District Judge

         Before the court is plaintiff's motion to determine the scope of the administrative record. Dkt. 31. The matter is fully briefed and suitable for decision without oral argument. Having read the parties' papers and carefully considered their arguments and the relevant legal authority, and good cause appearing, the court hereby rules as follows.

         BACKGROUND

          A. Procedural History

         This is an ERISA matter in which Myra Sugiyama has sued Unum Life Insurance Company (“Unum”) and the Cooley LLP Health and Welfare Plan. Sugiyama seeks $550, 000 in accidental death and dismemberment (“AD&D”) benefits under a policy issued to her brother John Paul Sugiyama through his employer Cooley LLP (“Cooley”). Dkt. 1.

         The instant motion concerns the scope of the administrative record. Plaintiff argues that because Unum missed a deadline in its response to her claim, the administrative record was closed as of April 25, 2016-the date that Unum's response was allegedly due. In plaintiff's view, whether the AD&D benefits were properly denied must be determined on the basis of the record as it existed on April 25, 2016.

         Unum maintains that its claim determination was timely because it notified plaintiff of an extension of time on May 2, 2016. On June 2, 2016, Unum denied plaintiff's claim for benefits, relying on a report from the California Highway Patrol (“CHP”) that Mr. Sugiyama was driving while intoxicated at the time of the car collision that led to his death. (Mr. Sugiyama survived that collision, but was fatally struck by a car after exiting his vehicle.) In Unum's view, Mr. Sugiyama's death was not covered because of exclusions for losses “resulting from” intoxication or the commission of a crime.

         B. Unum's Processing of Plaintiff's Claim

          Plaintiff's claim was hand delivered to Cooley on January 26, 2016. Curry Decl. Ex. F; Tracie Sugiyama Decl. ¶¶ 2-3. Cooley completed the form and sent the claim packet to Unum, which received it on February 4, 2016. Curry Decl. Ex. G-I. On February 5, 2016, Unum issued a letter to plaintiff acknowledging its receipt of the claim. Huffman Decl. Ex. A at 61-63. On March 7 2016, Unum sent plaintiff a letter informing her that it was “waiting” on “[p]olice and medical examiner reports” before it could make a claim decision. Huffman Decl. Ex. A at 185.

         On April 27, 2016, Unum sent a letter to the CHP requesting the accident report. On May 2, 2016, Unum sent a letter to plaintiff's counsel extending its response deadline an additional 90 days-which is permitted if “special circumstances” warrant-because Unum was waiting to receive the CHP report and the report from the Alameda County Coroner & Medical Examiner's (“ME”) office. Curry Decl. Ex. K (the “May 2 Letter”). On May 20, 2016, Unum formally requested the ME report. Curry Decl. Ex. L. On June 2, 2016, Unum denied plaintiff's claim for AD&D benefits based on the CHP and ME reports. Curry Decl. ¶ 9. Plaintiff sued in this court on August 31, 2016. Dkt. 1.

         DISCUSSION

         A. Legal Standard

         The parties do not address the appropriate standard to be applied to this motion. Effectively, plaintiff seeks partial summary judgment on the scope of the administrative record. The court will therefore apply Rule 56 standards.

         A party may move for summary judgment on a “claim or defense” or “part of . . . a claim or defense.” Fed.R.Civ.P. 56(a). Summary judgment is appropriate when there is no genuine dispute as to any material fact and the moving party is entitled to judgment as a matter of law. Id. When deciding a summary judgment motion, a court must view the evidence in the light most favorable to the nonmoving party and draw ...


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