4 pages. Excerpt: The Eleventh Circuit has held that the 'heightened' arbitrary and capricious standard of review previously used by the court in cases where a conflicted plan administrator decided a claim for benefits -- and its accompanying burden-shifting analysis -- does not survive the Supreme Court's recent decision in Metropolitan Life Ins. Co. v. Glenn, 128 S. Ct. 2343 (2008). Instead, where a plan grants the fiduciary discretionary authority to determine eligibility for benefits, a decision denying plan benefits should be reviewed under an arbitrary and capricious standard, with the reviewing court considering any conflict as 'a factor' in its decision.  MORE >>