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Fourth Circuit: Plan Administrator Must Affirmatively Obtain 'Readily Available Information' in Claims Determination
Benefits Bryan Cave Link to more items from this source
Dec. 30, 2014

"The Fourth Circuit held that by not contacting Ms. Harrison's psychologist, Wells Fargo 'chose to remain willfully blind' to readily available information that might have confirmed her claim of disability. The court noted that ERISA requires that an administrator use a 'deliberate, principled reasoning process' in claims determination. It does not require that the plan administrator 'scour the countryside in search of evidence' to bolster a participant's claim. But where potentially relevant information is readily available, the court noted, ERISA does not permit an administrator to 'shut his eyes' to that information." [Harrison v. Wells Fargo Bank, No. 13-2379 (4th Cir. Dec. 5, 2014)]

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