Doe v. Group Hospitalization & Medical Services’s Empirical Analysis
3 F.3d 80 · 1993
Citation profile
77 federal appellate · 23 district ·
How this case has been cited
Cited by 200 later decisions — most recently September 2022 · most notably Abatie v. Alta Health & Life Insurance (2006), Pinto v. Reliance Standard Life Insurance (2000)
77 federal appellate · 23 district ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 29 U.S.C. § 1002 (§ 3 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1051 (§ 201 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1104 (§ 404 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1132 (§ 502 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1133 (§ 503 of the Employee Retirement Income Security Act of 1974)
Relies on Firestone Tire and Rubber Company v. Bruch · Nantahala Power & Light Co. v. Thornburg · Pledger v. Medlock · Associated Grocers, Inc. v. Washington · Delaware v. New York
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 200 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[D]eference will be lessened to the degree necessary to neutralize any untoward influence resulting from the conflict.”
37 later decisions quote this exact passage · from the majority“if a benefit plan gives discretion to an administrator or fiduciary who is operating under a conflict of interest, that conflict must be weighed as a factor in determining whether there is an abuse of discretion.”
8 later decisions quote this exact passage · from the majority“In this case, Blue Cross insured the plan in exchange for the payment of a fixed premium, presumably based on actuarial data. Undoubtedly, its profit from the insurance contract depends on whether the claims allowed exceed the assumed risks. To the extent that Blue Cross has discretion to avoid paying claims, it thereby promotes the potential for its own profit. That type of conflict [of interest] flows inherently from the nature of the relationship entered into by the parties and is common where employers contract with insurance companies to provide and administer health care benefits to employees through group insurance contracts.”
7 later decisions quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.