Trustees of the Local No. 1, et al. v. Walker, No. 11-2051 (8th Cir. 2012)
Annotate this CaseEloise Walker, mother of the decedent, appealed the grant of summary judgment in favor of Pamela Wright-Dallas, the named beneficiary under the decedent's benefits plans. Walker argued that the district court erred because it made a ruling without first reviewing the entire administrative record, and in the alternative, the district court erred by applying the wrong standard of review. The court found no plain error and rejected Walker's claim that the district considered an inadequate record; the district court properly applied the abuse-of-discretion standard; and a heightened standard of review was not warranted. Accordingly, the court affirmed the judgment.
Court Description: Civil case - ERISA. Claim that district court considered an inadequate administrative record is rejected; district court properly applied the abuse- of-discretion standard in reviewing the Appeals Committee's decision; heightened standard of review was not warranted when procedural irregularities in the administrative process had no connection to the substantive decision reached.
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