• On remand from the United States Supreme Court’s 2010 decision in this case, which directed that judicial deference in ERISA cases should not be diminished simply because an administrator erred in one determination in an earlier stage of a benefit claim proceeding, the Federal District Court in the Western District of New York endorsed the administrator’s construction of certain plan provisions, and the participants appealed.  
  • DOL submitted amicus brief arguing for the application of a “reasonable expectation of participants” standard to an administrator’s interpretation of plan provisions.  
  • Various industry groups, including ERIC, submitted an amicus brief supporting broader deference for administrator, without a “reasonable expectations” limitation.  
  • The Second Circuit’s determination in this appeal should further clarify the scope of deference due to administrators in the wake of the Supreme Court’s three key decisions since 2008 on benefit claims, Glenn, Conkright, and Amara.