I gave an overview of this highly significant Ninth Circuit opinion in :: Ninth Circuit Requires Application Of Normal Summary Judgment Rules In Benefits Denial Review
Brian S. King, Esq., who regularly practices in that jurisdiction, (and a moderator on erisaboard.com) has posted a very helpful commentary on his site which gives a very valuable perspective on this case.
While the Ninth Circuit relied primarily on circuit precedent for its decision, it made clear that Glenn was consistent with its ruling. There is little question that Nolan is correct on this point. The case will likely serve as a guidepost for other circuit and district courts as they wrestle with how to properly apply the language of Glenn.
The entire commentary can be viewed here.