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The Elusive ERISA Standard of Review: Conflicts, Metaphors & Reversals
Health Plan Law 
Jan. 11, 2008
"In a case notable for medical evidence of 'cross cutting ambiguity', the Fourth Circuit held that the district court judge failed to appreciate the requirements of the abuse of discretion standard. This case is but one of a number of recent cases that illustrate the practical difficulties that attend the Supreme Court's standard of review analysis presented in Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 115 (1989)."
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