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Eleventh Circuit Panel Holds That Glenn Overrules Prior Precedent
Health Plan Law 
Sept. 19, 2008
Excerpt: According to the [Eleventh Circuit opinion in Doyle v. Liberty Life], 'Glenn implicitly overrules and conflicts with our precedent requiring courts to review under the heightened standard . . ' The panel substituted a new opinion for its prior opinion in the case, holding that 'heightened scrutiny' and burdenshifting requirements no longer apply. This note is cross-posted to ERISABoard.com where the opinion is attached.
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