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Reichard v. United Omaha Life Insurance Company

__ Fed. Appx. __ (2020)

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Reichard v. United Omaha Life Insurance Company

United States Court of Appeals for the Third Circuit
__ Fed. Appx. __ (2020)

  • Written by Robert Cane, JD

Facts

Giovanna Reichard (plaintiff) sought to make an insurance claim with United of Omaha Life Insurance Company (United of Omaha) (defendant). Reichard’s initial claim was denied, so she brought an administrative appeal. Dr. Reeder was United of Omaha’s senior vice president and a medical reviewer for the company. Dr. Reeder was the sole medical reviewer of Reichard’s administrative appeal. Dr. Reeder upheld the denial of Reichard’s claim. Reichard sued United of Omaha for improperly denying her claim, arguing that Dr. Reeder had a conflict of interest in his roles as medical reviewer and senior vice president. Reichard argued that Dr. Reeder had a financial incentive as senior vice president to deny benefits. In turn, Reichard sought discovery related to the allegations of Dr. Reeder’s conflict of interest. Specifically, Reichard sought information about the other appeals for which Dr. Reeder served as medical reviewer in order to determine Dr. Reeder’s rate of denials. Reichard filed a motion to compel discovery, which the district court denied. Reichard appealed, claiming that the district court abused its discretion in denying her motion to compel discovery.

Rule of Law

Issue

Holding and Reasoning (Bibas, J.)

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