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Text of Amended Ninth Circuit Opinion in Tibble v. Edison International (PDF)
U.S. Court of Appeals for the Ninth Circuit Aug. 2, 2013
"At least three considerations prompt us to hold that the Firestone framework can govern issues of plan interpretation even when they arise outside the benefits context. First, while the Firestone case did not announce a holding beyond benefits, its rationale did not stem from an interpretive gloss on the welfare-benefits provision of ERISA....Second, one reason the Court in Conkright rejected an exception the Second Circuit had carved out from Firestone deference was its potential to create 'uniformity problems.' ... Third, we observe that consistently applying Firestone to the question of what a plan means, 'by permitting an employer to grant primary interpretive authority over an ERISA plan to the plan administrator,' has the virtue of 'preserv[ing] the "careful balancing" on which ERISA is based.'"
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