White v. Coca-Cola Co.’s Empirical Analysis
542 F.3d 848 · 2008
Citation profile
6 federal appellate · 1 state decisions
How this case has been cited
Cited by 45 later decisions — most recently July 2022 · most notably Fleisher v. Standard Insurance (2012), Blankenship v. Metropolitan Life Insurance (2011)
6 federal appellate · 1 state decisions
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
Relies on Firestone Tire and Rubber Company v. Bruch · Metropolitan Life Insurance v. Glenn · Philpott v. Essex County Welfare Board · Sereboff v. Mid Atlantic Medical Services, Inc. · Jett v. Blue Cross & Blue Shield of Alabama, Inc.
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 45 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) Apply the de novo standard to determine whether the claim administrator’s benefits-denial decision is ‘wrong’ (i.e., the court disagrees with the administrator’s decision); if it is not, then end the inquiry and affirm the decision. (2) If the administrator’s decision in fact is ‘de novo wrong,’ then determine whether he was vested with discretion in reviewing claims; if not, end judicial inquiry and reverse the decision. (3) If the administrator’s decision is ‘de novo wrong’ and he was vested with discretion in reviewing claims, then determine whether ‘reasonable’ grounds supported it (hence, review his decision under the more deferential arbitrary and capricious standard). (4) If no reasonable grounds exist, then end the inquiry and reverse the administrator’s decision; if reasonable grounds do exist, then determine if he operated under a conflict of interest. (5) If there is no conflict, then end the inquiry and affirm the decision. (6) If there is a conflict of interest, then apply heightened arbitrary and capricious review to the decision to affirm or deny it.”
7 later decisions quote this exact passage · from the majority“After the Court determined that the administrator of an ERISA plan operated under a conflict, it considered “ ‘how1 [a] conflict ... should ‘be taken into account on judicial review of a discretionary benefit determination.’ ” Id. at 2350 (quoting MetLife v. Glenn, 552 U.S. 1161 , 128 S.Ct. 1117 , 169 L.Ed.2d 845 (2008) (mem.)). The Court concluded “that a conflict should ‘be weighed as a factor in determining whether there is an abuse of discretion.’ ” Id. (quoting Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 115 , 109 S.Ct. 948, 957 , 103 L.Ed.2d 80 (1989) (internal quotation marks omitted)). The Court explained that the consideration of a conflict as a factor did not require “a change in the standard of review” and criticized “special burden-of-proof rules, or other special procedural or evidentiary rules, focused narrowly upon the evaluator/payor conflict” that circuit courts had developed. Id. at 2351. The Court stated that “[b]enefits decisions” are too numerous in nature “to come up with a one-size-fits-all procedural system that is likely to promote fair and accurate review. Indeed, special procedural rules would create further complexity, adding time and expense to a process that may already be too costly for many of those who seek redress.” Id.”
1 later decision quote this exact passage · from the majority“even if there is evidence that would support a contrary decision.”
1 later decision 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.