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Does Supreme Court Prefer Administrative Remand for Erroneous ERISA Benefit Determinations?
Jackson Lewis LLP 
[Guidance Overview] June 24, 2010
Excerpt: It is plain that a majority of the Justices are prepared to vigorously defend, and arguably expand, Firestone deference after Conkright. Perhaps the majority was concerned that Glenn or its progeny may have called this stance into question. It would appear Conkright also may stand for the proposition that a possible remedy for wrongfully denied benefits may not be an award of benefits by the court, but a remand for further administrative review.
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