Wall v. Reliance Standard Life Insurance Company

Citation: Not availableDocket: Civil Action No. 2020-2075

Court: District Court, District of Columbia; March 27, 2023; Federal District Court

Original Court Document: View Document

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Lucas Wall, acting pro se, initiated a lawsuit against Reliance Standard Life Insurance Company and Dr. Tajuddin Jiva, alleging damages from the termination of his disability benefits. Wall asserts a count of medical malpractice against Dr. Jiva. Following referral to Magistrate Judge G. Michael Harvey for case management, Dr. Jiva filed a motion for judgment on the pleadings to dismiss the malpractice claim. On July 5, 2022, Judge Harvey recommended granting Jiva's motion. Wall subsequently objected to the recommendation and filed a motion to vacate a previous court order to reinstate certain counts of his complaint. The court reviewed the recommendation, Wall's objections, and the relevant legal context, ultimately adopting Judge Harvey's recommendation, granting Dr. Jiva's motion to dismiss, and denying Wall's motion to vacate the earlier order.

Wall's allegations include that Reliance administered his long-term disability benefits until their termination on January 29, 2020, after which he appealed the decision. Reliance conducted a peer review by Dr. Jiva, which Wall contested. Following an Independent Medical Examination, the termination of benefits was reversed. The procedural history includes Dr. Jiva's motion, Wall's opposition and objections, and subsequent filings from both parties.

Mr. Wall filed a Motion to Vacate Part of the Court’s June 1, 2021 Order on July 20, 2022, to which Dr. Jiva responded on August 2, 2022. The motion and opposition are now ready for adjudication. Under Federal Rule of Civil Procedure 72(b), parties may file specific written objections to a magistrate judge's recommended disposition, which the district court can accept, reject, or modify. A judge must review any properly objected portions de novo, while generalized objections receive clear error review. Objections must specifically identify contested findings and their basis; merely rehashing arguments does not qualify for de novo review. Additionally, a Rule 12(c) motion for judgment on the pleadings can be filed after pleadings are closed, granted when no material issues of fact remain, and is evaluated using the same standard as a Rule 12(b)(6) motion. Courts treat factual allegations in the complaint as true but do not accept legal conclusions, granting judgment only if the plaintiff cannot prove any set of facts that would entitle them to relief.

Mr. Wall's Motion to Vacate Part of the Court's June 1, 2021 Order is governed by Federal Rule of Civil Procedure 54(b) since there is no final judgment. Rule 54(b) allows a court to revisit orders that resolve fewer than all claims or parties before final judgment. The standard for granting such a motion is based on what justice requires, which includes considerations of whether the court misunderstood the parties, made decisions outside the presented issues, failed to consider controlling law, or if there has been a significant change in the law. The moving party must show a tangible harm from denial of reconsideration, and although the court has discretion to reconsider, this is limited by the law of the case doctrine, requiring a good reason to revisit settled issues.

Pro se litigants, like Mr. Wall, are afforded some leniency in terms of procedural standards but are still required to adhere to Federal Rules of Civil Procedure. Specifically, while their pleadings are liberally construed, they cannot disregard established rules.

Regarding Mr. Wall's medical malpractice claim, the Court affirms that New York law governs the case, rejecting his objection to the application of New York law over District of Columbia law. This conclusion is based on two points: the parties’ implicit agreement on the application of New York law and New York's greater interest in the dispute.

Mr. Wall objects to the conclusions regarding the applicable law for his medical malpractice claim against Dr. Jiva, who resides in New York, while Mr. Wall is a resident of the District of Columbia. The court, referencing Magistrate Judge Harvey's report, identifies New York and the District of Columbia as the only relevant jurisdictions for this choice-of-law issue. Mr. Wall asserts that he did not implicitly agree to New York law governing the dispute, claiming ignorance of choice-of-law principles as a pro se litigant, thus deserving deference. He argues that his references to laws from several other states indicate his lack of understanding regarding the choice-of-law question. 

Dr. Jiva counters that Mr. Wall waived his right to argue for the application of District of Columbia law by not presenting it in his earlier opposition to Dr. Jiva’s motion. The court agrees with this perspective, stating that parties can agree on the governing law, which waives objections to its application. Both parties have effectively agreed that New York law governs the malpractice claim, with Mr. Wall acknowledging this in his opposition brief. 

The court outlines the basic elements of a medical malpractice claim under New York law and emphasizes that New York does not differentiate between malpractice insurance for independent medical exams and traditional medical practice. Mr. Wall did not propose any alternative jurisdictional law, thus conceding that New York law applies. Furthermore, the court notes that failing to address certain arguments in opposition to a dispositive motion can lead to those arguments being treated as conceded.

Mr. Wall, as a pro se plaintiff, is subject to more lenient pleading standards; however, he failed to counter Dr. Jiva's argument that New York law governs his medical malpractice claim, effectively conceding the point. The Court notes that Mr. Wall specifically referenced New York law, further solidifying this agreement. Regarding the choice-of-law analysis, Mr. Wall acknowledges that Magistrate Judge Harvey applied the correct legal standard, which requires federal courts in diversity cases to follow the choice-of-law rules of their jurisdiction. The District of Columbia mandates an assessment of whether a "true conflict" exists between the laws of the involved jurisdictions. In this situation, the Court will utilize a modified governmental interests analysis, evaluating four factors: the location of the injury, the site of the conduct causing the injury, the domicile of the parties, and the location of their relationship. Mr. Wall contests the determination that the injury occurred in New York, claiming it transpired in the District of Columbia due to the revocation of his long-term disability benefits. Although Dr. Jiva does not address this argument, the Court agrees with Magistrate Judge Harvey that this factor does not favor either jurisdiction, asserting that the malpractice claim is distinct from the benefits issue, focusing instead on Dr. Jiva's adherence to the standard of care.

Mr. Wall's medical malpractice claim is valid as it does not conflict with ERISA, focusing on an injury separate from a denial of benefits. The injury is deemed to have occurred when Dr. Jiva sent his report to Reliance, rather than at the time of the benefits denial. Since the report was transmitted from New York to Pennsylvania, neither New York nor the District of Columbia has a strong claim based on this factor. 

Regarding the second factor, Mr. Wall argues that the conduct causing the injury occurred in D.C., asserting that Dr. Jiva's actions directly led to his injuries. However, the Court finds this unpersuasive, noting that Dr. Jiva acted in New York, thus favoring New York law. 

Mr. Wall also asserts that the fourth factor, concerning the parties' relationship, favors D.C. law, but he fails to provide a rationale for this claim. The Court agrees with Magistrate Judge Harvey that the relationship is centered in New York. 

Additionally, Mr. Wall argues that D.C. has a stronger interest in applying its law based on public policy concerns for residents receiving adequate medical care and the financial implications of denied benefits. However, the D.C. Circuit has established that the state where the defendant's conduct occurs holds the dominant interest in regulating the matter. As Dr. Jiva's conduct took place in New York, this factor also supports New York law.

Overall, the Court concludes that New York law governs Mr. Wall's medical malpractice claim, adopting Magistrate Judge Harvey's recommendation.

Mr. Wall's request to reinstate his previously dismissed negligence and bad faith claims against Dr. Jiva has been denied by the Court. Wall proposed two methods to achieve this: rejecting Magistrate Judge Harvey's recommendation that granted judgment on the pleadings for Dr. Jiva or vacating the Court's June 1, 2021 Order that dismissed those claims. The Court affirmed that Magistrate Judge Harvey correctly concluded there was no physician-patient relationship, which is essential for medical malpractice claims. Wall's arguments regarding the possibility of converting the medical malpractice claim into negligence and bad faith claims were found unpersuasive, as liability cannot be established without that relationship. Consequently, the Court adopted Harvey’s recommendation to grant judgment on the pleadings for Dr. Jiva.

Additionally, the Court considered Wall's motion to vacate the dismissal of his negligence and bad faith claims under Rule 54(b), which allows for revision of interlocutory judgments. The Court reiterated that such motions should be granted only as justice requires, but ultimately upheld its prior decision to dismiss the claims.

Justice may necessitate revising a prior opinion when the court has misunderstood a party, made a decision outside the issues presented, erred in understanding, or when there has been a significant change in law or facts. The court has broad discretion regarding Rule 54(b) motions for reconsideration. Dr. Jiva argues that Mr. Wall's Motion to Vacate is untimely due to significant delay, as the case has been pending for nearly two years and Dr. Jiva's Motion for Judgment for approximately four months. He compares the situation to motions for leave to amend a complaint after summary judgment, citing relevant case law that denies such motions if filed after considerable delays. However, the court finds no established deadline for filing a Rule 54(b) motion and considers Dr. Jiva’s arguments unpersuasive, noting the distinctions in cited cases. The court will address the merits of Mr. Wall's motion, which seeks to pursue negligence and bad faith claims, asserting that it is unjust to leave him without remedies against Dr. Jiva. Mr. Wall contends that the court overlooked his negligence claim against Dr. Jiva, claiming it does not relate to ERISA. However, the court clarifies that it previously analyzed his negligence claims and concluded they were preempted by ERISA, as they sought to review the termination decision and supplement ERISA remedies. Therefore, the court denies Mr. Wall's request to amend his complaint because the preempted claim would not survive a motion to dismiss, reinforcing that courts may deny such motions as futile if the proposed claim fails to withstand dismissal.

Mr. Wall's arguments regarding the Court's failure to consider New York caselaw for negligence claims and the specific allegations against Dr. Jiva are rendered moot, as state-law claims are preempted by ERISA, referencing Gobeille v. Liberty Mut. Ins. Co. The Court denies Mr. Wall’s motion concerning his negligence claim. Regarding the bad faith claim, Mr. Wall asserts that the Court did not provide legal authority for its dismissal and claims to have adequately stated his case in the Second Amended Complaint, incorporating his prior complaint from the New York State Department of Health. However, the Court reiterates that Mr. Wall has not established a common law cause of action for bad faith under District of Columbia law, as he failed to provide legal authority to support his claim against Dr. Jiva. The allegations of bad faith in the Second Amended Complaint pertain only to insurance companies, and without legal backing, Mr. Wall does not present a valid theory of liability. Consequently, the Court denies his Motion to Vacate concerning the bad faith claim. Ultimately, the Court adopts Magistrate Judge Harvey’s Report and Recommendation, grants Dr. Jiva’s Motion for Judgment on the Pleadings, and denies Mr. Wall’s Motion to Vacate. An appropriate order follows this Memorandum Opinion.