THE ETHICAL DIMENSION • The appellate court noted in this case that the district court’s decision—which granted benefits to Evans—might arguably have been a better decision under the facts. If the court believed that the district court’s conclusion was arguably better, then why did it reverse the decision? What does this tell you about the standards for review that appellate judges use?

WHAT IF THE FACTS WERE DIFFERENT? • Suppose that it was clear from the evidence on record that the ERISA administrator had not been careful and consistent and had rejected Evans’s claim merely because of a personal dislike for Evans. How might this fact have changed the result in this case?

Eaton Corporation is a multinational manufacturing company that funds and administers a long-term disability benefits plan for its employees. Brenda Evans was an employee at Eaton. In 1998, due to severe rheumatoid arthritis, Evans quit her job at Eaton and fi led for disability benefits. Eaton paid disability benefits to Evans without controversy prior to 2003, but that year, Evans’s disability status became questionable. Her physician had prescribed a new medication that had dramatically improved Evans’s arthritis. In addition, Evans had injured her spine in a car accident in 2002 and was claiming to be disabled by continuing back problems as well as arthritis. But diagnostic exams indicated that the injuries to Evans’s back were not severe, and she could cook, shop, do laundry, wash dishes, and drive about seven miles a day. By 2004, medical opinion on Evans’s condition was mixed. Some physicians who had examined Evans concluded that she was still disabled, but several other physicians had determined that Evans was no longer totally disabled and could work. On that basis, Eaton terminated her disability benefits. Evans filed a complaint in a federal district court alleging violations of the Employee Retirement Income Security Act of 1974. The district court examined the evidence in great detail and concluded that Eaton had abused its discretion in failing to find Evans’s examining physicians’ opinions more credible. Eaton appealed.