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District Court Adopts Agency Principles Deeming Employer Agent of Insurance Carrier
Health Plan Law 
[Guidance Overview] Dec. 11, 2008
Excerpt: The Thrall opinion's patina of historical retrospective on prior Ninth Circuit authority veils the court's remarkable decision to elevate state law notions of insurance law over uniformity in ERISA plan administration. The principal issue - when may an employer be deemed an agent of the insurance carrier for purposes of notice of a change in beneficiaries.
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