Clothier v. Health Care Service Corporation

CourtDistrict Court, W.D. Oklahoma
DecidedJune 15, 2023
Docket5:21-cv-00884
StatusUnknown

This text of Clothier v. Health Care Service Corporation (Clothier v. Health Care Service Corporation) is published on Counsel Stack Legal Research, covering District Court, W.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Clothier v. Health Care Service Corporation, (W.D. Okla. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA

MURIEL COLLEEN CLOTHIER, ) ) Plaintiff, ) ) v. ) No. CIV-21-884-R ) HEALTH CARE SERVICE ) CORPORATION, a foreign mutual legal ) reserve company, d/b/a BLUE CROSS ) AND BLUE SHIELD OF OKLAHOMA, ) ) Defendant. )

ORDER

This case arises from Defendant’s denial of insurance coverage for microwave ablation therapy (“MAT”) to treat Plaintiff’s cancerous lung tumors. The denial was allegedly based on a medical policy adopted by Defendant stating that MAT is experimental when used to treat more than one lung tumor. According to Plaintiff, the medical policy was incorrect, outdated, ambiguous, “arbitrarily drafted” and not incorporated into the insurance contract. Plaintiff asserts claims for breach of contract and breach of the duty of good faith and fair dealing. Now before the Court is Plaintiff’s Motion to Compel Discovery [Doc. No. 40] seeking responses to four interrogatories and five requests for production. Defendant objects to the requests as seeking irrelevant information and being unduly burdensome. Federal Rule of Civil Procedure 26(b)(1) provides that: [p]arties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties' relative access to relevant information, the parties' resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit. Information within this scope of discovery need not be admissible in evidence to be discoverable.

The scope of discovery under this rule is broad, but it “is not without limits and the trial court is given wide discretion in balancing the needs and rights of both plaintiff and defendant.” Gomez v. Martin Marietta Corp., 50 F.3d 1511, 1520 (10th Cir. 1995) (internal quotation omitted). When the relevance of a particular discovery request “is not readily apparent, the party seeking the discovery has the burden to show the relevance of the information requested.” Barton v. Tomacek, No. 11-CV-0619, 2012 WL 4735927, at *4 (N.D. Okla. Oct. 3, 2012). Conversely, when the discovery request appears relevant, the party resisting the request has the burden of showing that the request falls outside the scope of permissible discovery. Id. Having considered the parties’ submissions under these standards, the Court finds that Plaintiff’s motion should be denied. A. Interrogatories No. 12 and No. 13 After Defendant denied coverage for the MAT procedure, Plaintiff’s physicians requested an independent external review of the decision. The Oklahoma Insurance Department assigned the review to Dane Street, which upheld the denial of coverage. Interrogatory Nos. 12 and 13 ask Defendant to identify the number of times the doctors retained by Dane Street have reviewed claims for Defendant and the number of times the doctors have upheld a denial of coverage since January 1, 2016. Plaintiff contends this information is relevant for two reasons. First, she argues that the Dane Street doctors applied a different standard during

their review of Plaintiff’s claim and relied on a medical study that actually supports Plaintiff’s position. Plaintiff does not, however, explain how the numbers she seeks will shed any light on whether the doctors applied the wrong standard or reached the wrong conclusion with respect to her claim. Second, Plaintiff argues that these numbers can be used to show bias, i.e. that the

Dane Street doctors who reviewed Plaintiff’s claim have a tendency to side with the insurance company. Although a consistent pattern of siding with the insurance company may be relevant to the doctor’s credibility, the Court finds that any benefit from this information is outweighed by the burden on Defendant. Defendant has presented an affidavit indicating that it would need to manually sift through 4,000+ files to identify

claims reviewed by the specific doctors involved in this case and that this task would take approximately 2,220 hours to complete. Based upon this evidence, and the minimal relevance of the requested information, the Court concludes that Defendant has met its burden of showing that responding to these interrogatories would be unduly burdensome and not proportional to the needs of this case.

B. Requests for Production No. 11, No. 12, and No. 13 These requests seek all evidence of payments made to the individual Dane Street doctors for the review of Plaintiff’s claim, all evidence of payments made to the individual Dane Street doctors for review of medical appeals for the past ten years, and all evidence of payments made to Dane Street for review of Plaintiff’s claim. Defendant’s discovery responses state that the individual doctors who reviewed the claim for Dane Street are not agents or employees of Defendant, that it has made no payments directly to the individual

doctors, that it made no payments directly to Dane Street for its review of Plaintiff’s claim but was instead billed by the Oklahoma Insurance Department, and that the invoice related to Plaintiff’s claim has been produced. Plaintiff does not specifically address why these particular responses are deficient. It appears that Defendant has adequately responded to these requests.

C. Request for Production No. 14 Request for Production No. 14 seeks all evidence of payments made to Dane Street for review of medical appeals for the past ten years. Plaintiff argues the payments show the reviewing physicians have a financial incentive to side with the insurance company. The Court finds that the relevance of this request is slight and far outweighed by the undue

burden placed on Defendant in responding. Although evidence that a witness received payments or other financial incentives from a party is generally relevant to show bias, the fact that the Defendant paid Dane Street to conduct numerous external and internal reviews does not appear to be in dispute. Defendant states that 103 external review requests were assigned to Dane Street. State law

establishes that the insurer bears the cost of those reviews. See Okla. Stat. tit. 36, § 6475.16. Defendant has additionally stated that it directly engaged Dane Street to conduct 4,338 internal appeals. Given these statements, the benefit of obtaining “all evidence of payments” made to Dane Street over a ten-year period is minimal at best. See Murphy v. Deloitte & Touche Grp. Ins. Plan, 619 F.3d 1151, 1163 (10th Cir. 2010) (recognizing that benefit of allowing detailed discovery of administrator’s financial interest in ERISA claim “will often be outweighed by its burdens and costs because the inherent dual role conflict

makes that financial interest obvious”). Further, Defendant has presented evidence showing that it would likely need to spend over 2,000 hours manually searching multiple databases and redacting personal identifying information to respond to this request. Based upon this evidence, and the minimal relevance of the requested information, the Court concludes that Defendant has

met its burden of showing that responding to these interrogatories would be unduly burdensome and not proportional to the needs of this case. D. Interrogatories No. 17 and No. 18 and Request for Production No.

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Clothier v. Health Care Service Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/clothier-v-health-care-service-corporation-okwd-2023.