Excerpt: Crowell v. Shell presents a number of interesting issues, including an in-depth look at when supplemental retirement benefits conferred through 'letters of agreement' may constitute ERISA plans. The conflict of interest issue, however, is of particular interest given the fresh look it provides into how the Fifth Circuit will incorporate that holding into its precedent on judical review of benefit denials. It appears the Court has acknowledged at least one significant change. When a plan administrator operates under a conflict of interest?

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