Procedural Errors Don't Alter Standard of Review In ERISA Claim for Benefits

The Ninth Circuit recently held that where an ERISA plan provides the plan administrator discretionary authority to determine benefit claims, procedural violations that occur during the course of the administrative claims process "do not alter the standard of review unless those violations are so flagrant as to alter the substantive relationship between the employer and employee, thereby causing the beneficiary substantive harm." Here, Plaintiff John Nasi alleged that the district court erroneously reviewed the administrator's denial of benefits under an abuse of discretion standard.



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