Standard of Review

:: District Court Permits Supplementation Of Record But With Instruction On Law

ERISA provides federal courts with jurisdiction to review benefits determinations made by fiduciaries or plan administrators. 29 U.S.C. § 1132(a)(1)(B); see also Lopez ex rel. Gutierrez v. Premium Auto Acceptance Corp., 389 F.3d 504, 509 (5th Cir. 2004). A district court’s function when reviewing ERISA claims is like an appellate court’s. “[The court] does not …

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Eighth Circuit Holds Mental Health Treatment Limitation Inapplicable

“ . . . [I]n order for Principal to reasonably deny S.W.’s hospital charges, substantial evidence had to support its determination that the primary focus of her hospitalization was mental health treatment, i.e., treatment designed to alter her behavior. While there is certainly evidence that mental health treatment was one focus of S.W.’s hospitalization, we …

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Stricter Review of Benefits Denial Where Plan Terms Inadequately Disclosed

[P]lan administrators must create written plan documents and offer members an opportunity to examine those documents to “determine exactly what [their] rights and obligations are under the plan.” Id. (quoting H.R. Rep. No. 93-1280, at 297 (1974), reprinted in U.S.C.C.A.N. 4639, 5077, 5078). Given the members’ right to examine the documents, the plan administrator must …

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