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ERISA Standards of Review and the Administrator's Conflict of Interest (PDF)
Utah Bar Journal 
Oct. 25, 2005
Pages 20-23 of 64. Excerpt: The Tenth Circuit Court of Appeals recently provided helpful guidance for district courts evaluating claims of wrongful denial of employee benefits under ERISA. In particular, the court clarified the standard of review to be applied where the plan administrator of the employee benefit plan had a potential conflict of interest at the time the benefits were denied.
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