ERISA Standard of Review

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Warner v. Unum Life Ins.Co. of America, 2013 U.S.Dist.LEXIS 105067 (N.D.Ill. July 26, 2013)(Issue: Discovery)

Click Here Despite the applicability of the arbitrary and capricious standard of review, the court granted in substantial part the plaintiff’s motion to compel discovery. Although the court acknowledged that in the Seventh Circuit, the scope of a court’s review of an ERISA benefit denial under a deferential standard of review is limited to the “administrative” […]

Court Ruling Expands Scope of ERISA Discovery

A decision by a federal court has expanded the scope of discovery available in ERISA cases. In Williams v. FedEx Corp. Servs., Inc., No. 19 C 5706, 2021 WL 2854244 (N.D. Ill. July 8, 2021), the plaintiff sought to depose a plan administrator, but the defendant argued that the administrator was not a proper deponent because he was not involved in the initial denial of the claim. The court ultimately allowed the deposition, ruling that the administrator had information relevant to the plaintiff’s claim.