Aboul-Fetouh v. Employee Benefits Committee’s Empirical Analysis

Citation profile

10 federal appellate ·

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “A plan administrator’s interpretation or application of the plan, including a denial of plan benefits challenged under § 1132(a)(1)(B), is reviewed de novo “unless the benefit plan gives the administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the terms of the plan.” Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 , 109 S.Ct. 948, 956-57 , 103 L.Ed.2d 80 (1989). Many plans, like the Entergy plan at issue here, vest plan administrators with broad discretion to interpret and apply to the plan. In such cases, the “administrator’s interpretation of the plan and action based thereon” is reversed only for “an abuse of discretion.” Spacek v. Maritime Ass’n, 134 F.3d 283, 292 (5th Cir.1998) (citing Bruch, 109 S.Ct. at 956 ). The abuse of discretion standard applicable here is sometimes referred to or equated with an “arbitrary and capricious” standard of review. See Matassarin v. Lynch, 174 F.3d 549, 563 (5th Cir.1999), cert. denied, 528 U.S. 1116 , 120 S.Ct. 934 , 145 L.Ed.2d 813 (2000); Penn v. Howe-Baker Eng’rs, 898 F.2d 1096 , 1100 & n. 2a (5th Cir.1990).”

   1 later decision quote this exact passage · from the majority
   e.g. 189 F. Supp. 2d 559 - Hobbs v. Stroh Brewery Co.

2. ““[T]he abuse of discretion standard may involve a two-step process.” Spacek, 134 F.3d at 292 . First, the court determines whether the administrator’s interpretation of the plan is legally correct. Id. at 292 ; Threadgill v. Prudential Securities Group, Inc., 145 F.3d 286, 292 (5th Cir.1998). For this analysis, plan language is preeminent. If the court determines that the plan administrator’s interpretation of the plan is legally correct, then the administrator’s interpretation and the denial of benefits should be upheld because there cannot have been any abuse of discretion. See Spacek, 134 F.3d at 292 .”

   1 later decision quote this exact passage · from the majority
   e.g. 189 F. Supp. 2d 559 - Hobbs v. Stroh Brewery Co.

3. “Any review of an ERISA benefit determination must begin with the relevant plan language.”

   1 later decision quote this exact passage · from the majority
   e.g. Baker v. Metropolitan Life Insurance