Legal Alert: Second Circuit Reassesses Standard of Review Governing Challenges to Conflicted ERISA Plan Administrators' Benefits Decisions

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Citing the U.S. Supreme Court's decision in Metropolitan Life Insurance Co. v. Glenn, the Second Circuit recently issued one of the first major opinions to "reassess [the] standard of review governing cases … that challenge an Employee Retirement Income Security Act ('ERISA') plan administrator's decision to deny disability benefits, where the administrator has a conflict of interest because it both has the discretionary authority to determine the validity of the employee's claim and pays the benefits under the policy." McCauley v. First Unum Life Ins. Co., (Dec. 24, 2008).

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