Forum
U.S. Supreme Court
Case Status
Decided
Docket Number
08-810
Term
2009 Term
Oral Argument Date
January 20, 2010
Questions Presented
1. Whether the Second Circuit erred in holding, in conflict with decisions of this Court and other Circuits, that a district court has no obligation to defer to an ERISA plan administrator's reasonable interpretation of the terms of the plan if the plan administrator arrived at its interpretation outside the context of an administrative claim for benefits.
2. Whether the Second Circuit erred in holding, in conflict with decisions of other Circuits, that a district court has "allowable discretion" to adopt any "reasonable" interpretation of the terms of an ERISA plan when the plan interpretation issue arises in the course of calculating additional benefits due under the plan as a result of an ERISA violation.
Case Updates
Outcome
April 21, 2010
The Supreme Court held that federal courts should apply a deferential standard of review to ERISA administrators' interpretations of benefit plans. The decision reverses a Second Circuit ruling that had given greater authority to federal courts to interpret the terms of ERISA plans. The Supreme Court noted that the prior ruling threatened the predictability and uniformity of ERISA plan interpretation.
U.S. Chamber urges Supreme Court to reverse interpretation of ERISA plans
September 21, 2009
NCLC urged the Supreme Court to reverse a Second Circuit decision giving greater authority to district courts to interpret the terms of an ERISA plan. In this case, Xerox employees filed suit against their ERISA administrator for allegedly calculating ERISA plan benefits improperly. The Second Circuit held that a federal court can exercise “remedial discretion” to decide the proper amount of benefits following the invalidation of an administrator's interpretation. In its brief, NCLC argued that it is the plan administrator who is best suited to interpret often complex ERISA plans. The Second Circuit's ruling threatens the stability and predictability of ERISA plans by subjecting decisions that plan administrators make to being overturned in court, even if the plan administrator's interpretation and application of the plan is reasonable.