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Reinstatements Revisited: Tate v. Long-Term Disability Plan for Salaried Employees
Health Plan Law 
[Guidance Overview] Sept. 25, 2008
"After just reviewing the 7th Circuit decision in Hackett v. Xerox Corp. Long-Term Disability Income Plan, 315 F.3d 771 (7th Cir. 2003), so influential in Pannebecker v. Liberty Life Assur. Co., 2008 U.S. App. LEXIS 19753 (9th Cir. Ariz. Sept. 18, 2008), I find this recent decision from the 7th Circuit curious. This appears to be a case where the plan decision should fall in Category #2, as benefits were previously approved, but later terminated without a principled decision. Therefore, under Hackett, benefits should be reinstated."
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