4th Cir: “Proof Satisfactory to the Administrator” = De Novo Review of Benefit Claims
Thanks to friend of the blog, Jon Harkavy, for sending along this potentially important ERISA denial of benefit claim case from the 4th Circuit. In Cosey v Prudential, (4th Cir. Nov. 12, 2013), the Fourth Circuit held that the common plan formulation “proof satisfactory to the administrator” does not unambiguously confer discretion on the administrator and …
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