SPD Language Alone Did Not Grant Firestone Discretion: Ninth Circuit | Practical Law
In Prichard v. Metropolitan Life Ins. Co., the US Court of Appeals for the Ninth Circuit addressed the appropriate standard of review in a benefits dispute under an employer's long-term disability plan. The court concluded that discretionary language in a summary plan description could not grant Firestone discretionary authority where the plan's insurance certificate lacked language sufficient to confer discretionary authority.