A district court in North Carolina recently reaffirmed the principle that decisions made by a plan administrator are entitled to deferential review if the plan grants dictionary authority to the administrator. The court rejected a former employee’s argument that the administrator’s discretionary authority to determine his eligibility for benefits under a company severance plan may be limited because the plan provides that the administrator must act “in good faith” when making decisions. Noting that the employee would have the court first make a determination of whether the administrator acted in good faith before determining the appropriate standard of review, the district court found that, on the contrary, the phrase “made in good faith” confers discretionary authority on the administrator and limits review to determining whether the administrator’s interpretation of the plan was reasonable and in good faith. On a related issue, the court found that the employer failed to comply with the procedural requirements of the Employee Retirement Income Security Act of 1974 when it denied the employee’s claim for benefits by not giving a written explanation of the denial and appeal procedures. However, the court held that the appropriate remedy for the violation was not an award of severance benefits, as requested by the employee, but the remand of the case to the plan administrator for a reconsideration of the employee’s claim for benefits. (Dippel v. Philips Products Inc., W.D.N.C. 2011)