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Eleventh Circuit Eliminates "Heightened" Standard of Review for Benefit Claim Decisions


by Alston & Bird LLP View Firm Credentials
Atlanta Office

October 7, 2008

Previously published on September 25, 2008

The Eleventh Circuit has held that the "heightened" arbitrary and capricious standard of review previously used by the court in cases where a conflicted plan administrator decided a claim for benefits - and its accompanying burden-shifting analysis - does not survive the Supreme Court's recent decision in Metropolitan Life Ins. Co. v. Glenn, 128 S. Ct. 2343 (2008).


 

The views expressed in this article are solely the views of the author and not Martindale-Hubbell. This article is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance.




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