A three-judge panel of the Eleventh Circuit recently issued a decision urging the Court to reconsider the heightened review standard the Court currently applies in reviewing ERISA plan administrators? benefits determinations in conflict of interest situations. See Doyle v. Liberty Life Assurance Co. (11th Cir. Jan. 7, 2007). Although the Court in Doyle applied the Eleventh Circuit?s current standard and reversed the trial court?s grant of summary judgment in favor of the plan administrator, the panel urged the Court to reconsider this standard, which it described as ?unworkable.?

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