TIMOTHY J. SULLIVAN, Magistrate Judge.
This Memorandum Opinion addresses Defendant Guardian Life Insurance Company of America's ("Guardian") Motion for Judgment on the Pleadings (ECF No. 45), Plaintiff Rosemarie Brown's Response (ECF No. 46), and Guardian's Reply (ECF No. 47). For the reasons stated herein, Guardian's Motion for Judgment on the Pleadings is DENIED. This Memorandum Opinion and Order disposes of ECF Nos. 45, 46, and 47.
A. Standard of Review
Federal Rule of Civil Procedure 12(c) provides that "[a]fter the pleadings are closed-but early enough not to delay trial-a party may move for judgment on the pleadings." A motion for judgment on the pleadings pursuant to Rule 12(c) is analyzed under the same standard as a Rule 12(b)(6) motion to dismiss. Burbach Broad. Co. of Del. v. Elkins Radio Corp., 278 F.3d 401, 405-06 (4th Cir. 2002). The court must "accept all well-pleaded allegations in the plaintiff's complaint as true and draw all reasonable factual inferences from those facts in the plaintiff's favor." Edwards, 178 F.3d at 244. The plaintiff's "[f]actual allegations must be enough to raise a right to relief above the speculative level." Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007). "[O]nce a claim has been stated adequately, it may be supported by showing any set of facts consistent with the allegations in the complaint." Id. at 563. A complaint attacked by a motion to dismiss will survive if it contains "enough facts to state a claim to relief that is plausible on its face." Id. at 570. When a court considers matters outside the pleadings, a motion under Rule 12(b)(6) or (c) must be treated as a motion for summary judgment under Rule 56 and "all parties must be given a reasonable opportunity to present all the material that is pertinent to the motion." Fed.R.Civ.P. 12(d).
Here, both Guardian and Plaintiff present matters outside the pleadings, and the Court will treat the Motion as a motion for summary judgment. Guardian and Plaintiff each, for example, refer to this Court's opinion (ECF No. 41) denying Guardian's Motion for Summary Judgment (ECF No. 17). This opinion is based almost entirely on matters outside the pleadings. Ordinarily, when a motion for judgment on the pleadings is converted to a motion for summary judgment, a court must afford a reasonable opportunity for discovery to the parties and must permit an opportunity for the non-moving party to present matters outside the pleadings. Gay v. Wall, 761 F.2d 175, 177 (4th Cir. 1985). Because I will deny Guardian's Motion, it is unnecessary at this time to provide the parties an opportunity to engage in discovery or to permit Plaintiff an opportunity to submit matters outside the pleadings.
In reviewing the evidence related to a motion for summary judgment, the Court considers the facts in the light most favorable to the non-moving party. Ricci v. DeStafano, 557 U.S. 557, 585 (2009); George & Co., LLC v. Imagination Entm't Ltd., 575 F.3d 383, 391-98 (4th Cir. 2009); Dean v. Martinez, 336 F.Supp.2d 477, 480 (D. Md. 2004). Unless otherwise stated, the background provided here is comprised of undisputed facts. Where a factual dispute between the parties exists, the facts are considered in the light most favorable to the non-moving party.
B. Summary of the Facts
Judge Grimm's opinion dated December 5, 2012 (ECF No. 41) provides a fair summary of the factual background of this case. For clarity, I will summarize below those facts that are most critical to my analysis and decision. Plaintiff's son, Kenneth Clarke, worked for Defendant Emmitsburg Glass Co. ("Emmitsburg") and participated in a group life and disability insurance policy ("the policy"). Plaintiff was the designated beneficiary under Kenneth Clarke's policy. Upon Kenneth Clarke's death, Plaintiff did not initially file a claim for death benefits under the policy. Instead, Heather Allison Clarke ("Mrs. Clarke"), Kenneth Clarke's widow, filed a claim. After Mrs. Clarke's claim was denied, Plaintiff submitted a letter to Guardian that served as an appeal of the denial of death benefits under the policy. The letter was written on Plaintiff's letterhead and submitted with Plaintiff's signature, but it referenced the claim number that Mrs. Clarke had initially submitted. Guardian denied Plaintiff's appeal, but denied it as a claim.
Guardian insists that because Judge Grimm construed Plaintiff's appeal as an appeal of the denial of Mrs. Clarke's claim, rather than Plaintiff's personal claim, the Court must now find that while Plaintiff may have exhausted Mrs. Clarke's administrative remedies, Plaintiff has not exhausted her personal administrative remedies. As a result, Guardian argues, Plaintiff lacks standing to maintain this action. Plaintiff opposes Guardian's motion, and argues that even if Plaintiff did not technically follow the procedures to exhaust her administrative remedies as the beneficiary, she still has standing to maintain this action.
II. ARTICLE III STANDING
Guardian's sole argument is that Plaintiff lacks standing to maintain this action because, under Guardian's analysis, Plaintiff is suing on behalf of Mrs. Clarke. ECF No. 45-1 at 5. This is not the case. Plaintiff brought this action as the beneficiary of her son's insurance policy. ECF No. 2 at 1. Plaintiff did not bring this action, as Guardian contends, on behalf of Mrs. Clarke. Judge Grimm previously determined that "Plaintiff exhausted her administrative remedies prior to filing her Complaint." ECF No. 41 at 7. Guardian contends that, given that Plaintiff exhausted her administrative remedies with regard to Mrs. Clarke's claim for benefits, she now lacks standing to maintain this action to recover benefits for Mrs. Clarke and cannot assert "representational standing." ECF No. 45 at 4-5. Guardian's argument confuses the exhaustion requirement generally imposed upon ERISA claimants with principles of constitutional standing under Article III.
The plaintiff in a federal action bears the burden of demonstrating that she possesses standing to pursue her claims in federal court. To demonstrate standing, a plaintiff must show that: (1) she has suffered an injury in fact; (2) the injury is fairly traceable to the defendant's actions; and (3) the injury is likely to be redressed by a favorable decision of the court. Lujan v. Defenders of Wildlife, 504 U.S. 555, 560-61 (1992). The injury alleged must not be speculative, but must be "concrete and particularized" as well as "actual and imminent." Id. at 560. Further, it is essential that the injury have been caused by the defendant's conduct and not by the conduct of a third party beyond the court's control. See Frank Krasner Enterprises, Ltd. v. Montgomery County, 401 F.3d 230, 234-35 (4th Cir. 2005). "Standing is determined at the commencement of a lawsuit." Pashby v. Delia, 709 F.3d 307, 316 (4th Cir. 2013) (citing Lujan, 504 U.S. at 571 n.5 (1992)). "When standing is challenged on the pleadings, we accept as true all material allegations of the complaint and construe the complaint in favor of the complaining party." David v. Alphin, 704 F.3d 327, 333 (4th Cir. 2013) (citing Pennell v. City of San Jose, 485 U.S. 1, 7 (1988)).
Here, Plaintiff unmistakably has standing. In her Complaint, Plaintiff alleges that, as the policy beneficiary, she is owed certain benefits that the defendants refuse to pay. ECF No. 2 at 1. This injury is not speculative, but is an injury that is actual and particularized. Plaintiff's Complaint goes on to trace her injury to the defendants' conduct by alleging that Guardian refused to pay the policy benefits owed to her "despite repeated demands." Id. Finally, Plaintiff's injury could be redressed by a favorable ...