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Overview of Circuit Split Over Benefit Claims Against Plan Administrators
Health Plan Law 
May 3, 2007
"This case addresses the question of whether an ERISA plan is the only proper defendant in a claim based upon ERISA § 502(a)(1)(B). Under the facts, the defendant claims administrator, Sedgwick, argued that the plaintiff could not assert an ERISA § 502(a)(1)(B) claim against it, but only against the plan. The courts are not agreed on how to answer this question."
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