2022 U.S. App. LEXIS 10737 (4th Cir.)

1. What was the legal issue in this case? What did the appeals court decide?

2. On what basis did the Central States health plan deny Ms. Garner's claim for coverage of her back surgery? Why is judicial review in this case limited to consideration of whether administrators of the Central States health plan abused their discretion in denying this claim?

3. Why does the court decide that the health plan's administrators did, in fact, abuse their discretion and wrongly withhold a medical benefit, in violation of ERISA?

4. The court says that its decision in the case does not rest upon a finding that plan administrators acted in bad faith or deliberately withheld documentation. Why then, do you suppose that they acted as they did? Might the fact that this was a "back case" have had some bearing on their actions? Why or why not?

5. The court decided in this case not to remand the case to the plan administrators for anotherpresumably more properreview, as is often done in ERISA denial of benefits cases. Do you agree with this decision? Why or why not?