Edwards v. Guardian Life Insurance of America

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF MISSISSIPPI ABERDEEN DIVISION

JAMES “JIMMY” EMMETT EDWARDS PLAINTIFF

V. CIVIL ACTION NO. 1:22-CV-145-KHJ-MTP

GUARDIAN LIFE INSURANCE OF AMERICA DEFENDANT

ORDER Before the Court is Plaintiff Jimmy Edwards’s [37] Motion to Appeal the Magistrate Judge’s [36] Case Management Order. For the reasons below, the Court denies Edwards’s motion and upholds Magistrate Judge Michael T. Parker’s Case Management Order. I. Background This case arises from a dispute over a life insurance policy. Compl. [1]. Until her death, Mrs. Edwards owned and operated Allure Salon in Starkville, Mississippi. Edwards Aff. [17-1] at 1. Mrs. Edwards worked with other beauty technicians, but the parties disputed whether they were employees or independent contractors. , Def.’s Mem. Supp. Mot. Summ. J. [13] at 1; Pl.’s Mem. Opp’n Mot. Summ. J. [18] at 3. The Court’s [34] Order Granting Partial Summary Judgment resolved this dispute and held that the insurance policy was an ERISA-governed employee benefit plan. at 16 (“The circumstances show that the Guardian- issued life insurance policy is an ERISA plan.”). In effect, the Court recognized the technicians as employees instead of independent contractors. Following the Court’s [34] Order, the parties participated in a case management conference. Initial Order [35]. And on September 8, 2023, the Magistrate Judge issued a [36] Case Management Order setting out the deadlines

for the case. Edwards appeals the Case Management Order because it limits discovery to the administrative record absent further order of the Court. [37] at 1. II. Standard The Court will uphold a magistrate judge’s non-dispositive order unless it is “clearly erroneous or contrary to law.” 28 U.S.C. § 636(b)(1)(A); , 755 F.3d 802, 806 (5th Cir. 2014) (“A magistrate judge’s non- dispositive order may only be set aside if it ‘is clearly erroneous or contrary to law.’”

(quoting FED. R. CIV. P. 72(a))); L.U.CIV.R. 72(a)(1)(B) (“No ruling of a magistrate judge . . . will be . . . modified on appeal unless . . . the magistrate judge’s ruling is clearly erroneous or contrary to law.”). A factual finding is “clearly erroneous” when the reviewing court “on the entire evidence . . . is left with a definite and firm conviction that a mistake has been committed.” , No. 1:22-CV-48, 2023

WL 4824925, at *1 (N.D. Miss. July 27, 2023) (citing , 333 U.S. 364, 395 (1948)). In making this determination, “the district court is not permitted to receive further evidence; [rather,] it is bound by the clearly erroneous rule in reviewing questions of fact.” , 755 F.3d at 808 n.15. III. Analysis At the start, the Court recognizes Edwards’s attempt to use this appeal to request reconsideration of the Court’s prior Order. [37] at 2 (arguing the Court

can revise its previous ruling that “held . . . the workers at the Allure Salon were employees” for ERISA purposes); Order [34] (granting partial summary judgment and denying discovery requests). The Court declines to entertain that attempt. Edwards had 28 days from the Court’s Order to move to alter or amend the judgment. , 23 F. Supp. 3d 679, 703 (S.D. Miss. 2014) (recognizing the Rules “do not explicitly recognize a motion for reconsideration,” but courts “consider such motions under [Rule] 59(e) (motion to

alter or amend a judgment), when they are filed within [28 days]”). Edwards did not file a Rule 59(e) motion within 28 days, so the Court considers only Edwards’s appeal of the Magistrate Judge’s Case Management Order. Edwards appeals the following portion of the Magistrate Judge’s Case Management Order: DISCOVERY/OTHER MOTIONS: As this is an ERISA matter and such matters are generally decided based on the administrative record, no discovery is permitted absent further order of the court. Should either party determine that any discovery is necessary or appropriate, a motion and brief requesting same shall be filed. The deadline for filing such motions and for all other motions (except dispositive motions as noted above) is November 1, 2023.

[36]. Edwards has not been denied a specific discovery request. Rather, he appeals the Case Management Order because it “disallow[s] discovery, except when [Edwards] petitions the Court on each specific issue he might seek discovery.” [37] at 3. But this is an ERISA matter, and a court reviewing an ERISA matter is generally “limited to considering the evidence within the administrative record.”

, No. 1:11-CV-228, 2012 WL 12863147, at *3 (S.D. Miss. Dec. 5, 2012) (collecting cases), , 754 F.3d 324 (5th Cir. 2014). In short, the Magistrate Judge’s Case Management Order reiterates the Court’s finding that ERISA applies, [34], along with the general principle of limiting discovery to the administrative record in ERISA matters. The Case Management Order also allows Edwards to seek more discovery items with the

Court’s permission.1 Based on those considerations, the Court cannot say the Magistrate Judge’s Case Management Order is clearly erroneous or contrary to law. IV. Conclusion The Court has considered all arguments. Those not addressed would not have changed the outcome. For the stated reasons, the Court DENIES Edwards’s [37] Motion to Appeal and upholds Magistrate Judge Michael T. Parker’s [36] Case

Management Order. SO ORDERED, this 26th day of October, 2023. s/ UNITED STATES DISTRICT JUDGE

1 The Court reiterates that Edwards has not filed a motion requesting specific items of discovery; the Court has not had an opportunity to grant or deny a request.