Excerpt: 'Woods' presents a typical disability case set of facts, but the decision illuminates the all-important issue of what language suffices to vest discretion in the plan administrator. This language of grant has the consequence, of course, of stipulating the standard of review of claims denials should a federal district court be asked to review the claims denial. Of the eve of a decision in MetLife v. Glenn, this case serves as one of the most propitious points of departure one might imagine.

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