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3rd Circuit Court Says Stricter Standard Needed in Kosiba v. Merck & Co. ERISA Case
The Legal Intelligencer in Law.com 
Sept. 14, 2004
Excerpt: In its June 2000 decision in Pinto v. Reliance Standard Life Insurance Co., the 3rd U.S. Circuit Court of Appeals ruled that 'heightened scrutiny' is required when an insurance company both funds and administers an ERISA benefits plan since the combination of such fiduciary and non-fiduciary roles creates an inherent conflict of interest.
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