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Pierre v. Connecticut Gen. Life Ins. Co.

United States Court of Appeals for the Fifth Circuit

June 18, 1991

No. 89-3861

Opinion

 [*1553]  JOLLY, Circuit Judge

This case is before us for a second time. It requires us to determine the appropriate standard for review of factual determinations made by plan administrators under ERISA. The plaintiff brought suit for the denial of accidental death benefits under her husband's ERISA plan. In the first round, the district court applied the then proper standard of arbitrary and capricious review to the decisions of the ERISA plan administrator. Accordingly, it allowed the administrator to consider "hearsay" evidence, and concluded that the administrator's denial of the plaintiffs' claim was not arbitrary or capricious. On appeal, this court affirmed. 866 F.2d 141 (1989). Shortly thereafter, the Supreme Court decided Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 109 S. Ct. 948, 103 L. Ed. 2d 80 (1989), mandating de novo review for certain decisions by ERISA plan administrators. We vacated our previous opinion and remanded the case for further proceedings in the light of [**2]  Bruch. 877 F.2d 345. On rehearing, the district court applied de novo review and excluded the hearsay evidence. It then proceeded to reject the plan administrator's decision, and entered judgment for the plaintiff. The defendant appeals. As we explain in further detail below, we hold that Bruch does not require de novo review for factual determinations such as those in this case. Rather, we conclude that an abuse of discretion standard of review is appropriate in this case. Applying that standard, we reverse the decision of the district court.

The relevant facts are straightforward. The defendant, Connecticut General Life Insurance Company/Life Insurance Company of North America (hereinafter "Connecticut General") issued to Martin Marietta Corporation two insurance policies to fund claims under its employee welfare benefit plan. The plaintiff-appellee's husband, James Pierre, was employed by Martin Marietta and participated in its employee insurance benefit plan. He was shot to death during the early morning of October 26, 1986.

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932 F.2d 1552 *; 1991 U.S. App. LEXIS 12348 **; 13 Employee Benefits Cas. (BNA) 2566

Celestine PIERRE and the Estate of James Nolan Pierre, Jr., Plaintiffs-Appellees, v. CONNECTICUT GENERAL LIFE INSURANCE COMPANY/LIFE INSURANCE COMPANY OF NORTH AMERICA, Defendant-Appellant

Subsequent History:  As Corrected.

Prior History:  [**1]  Appeal from the United States District Court for the Eastern District of Louisiana. No. CA-87-5554-D; A. J. McNamara, Judge.

Disposition: Reversed and Remanded.

CORE TERMS

factual determination, de novo review, plan administrator, benefits, fiduciary, district court, arbitrary and capricious, interpretations, benefit plan, discretionary authority, principles, deceased, terms, denial of benefits, standard of review, trust law, discretionary, deference, hearsay, deferential standard, eligibility, accidental, abuse of discretion standard, determinations, decisions, exercises, appropriate standard of review, contract interpretation, terms of the plan, de novo standard

Governments, Fiduciaries, Pensions & Benefits Law, ERISA, General Overview, Employee Benefit Plans, Welfare Benefit Plans, Fiduciaries, Fiduciary Responsibilities, Plan Administration, Adherence to Plan, Civil Procedure, Appeals, Standards of Review, De Novo Review, Judicial Review, De Novo Standard of Review, Civil Litigation, Handling of Claims, ERISA Pension Plan Qualification Requirements, Child & Spouse Benefit Rules, Qualified Domestic Relations Orders, Business & Corporate Compliance, Pensions & Benefits Law, Plan Establishment, Claim Procedures, Named Fiduciary Appointment & Obligations, Abuse of Discretion, Estate, Gift & Trust Law, Trusts, Administrative Law