"[The 10th Circuit Court of Appeals] will not permit Defendant to sandbag Plaintiff with its after-the-fact interpretation of an entirely different section of the Plan.... Thus, not only was the [federal district court] not required to defer to Defendant's post hoc interpretation of these newly asserted provisions, but the district court should not even have considered this interpretation in the first place.... Consistent with our precedent, [this court] will consider only the specific basis upon which the Plan administrator relied in its administrative denial of benefits." (Spradley v. Owens-Illinois Hourly Employees Welfare Benefit Plan, Tenth Circuit Court of Appeals 10-7100, June 10, 2012)  MORE >>