American Journal of Law & Medicine

ERISA: fiduciary decisions in ERISA subject to abuse of discretion review - Booth v. Wal-Mart Stores, Inc.

ERISA: Fiduciary Decisions in ERISA Subject to Abuse of Discretion Review--Booth v. Wal-Mart Stores, Inc.(1)--The United States Court of Appeals for the Fourth Circuit held that abuse of discretion, not arbitrary and capricious, was the appropriate standard of review for a fiduciary's discretionary decision of an employee welfare benefit plan regulated by the Employee Retirement Income Security Act of 1974 (ERISA).(2) The court clarified the abuse of discretion standard by articulating relevant factors to be considered in determining whether a fiduciary had abused its discretion.(3)

Barbara Booth, an employee of Wal-Mart Stores, enrolled in its self-funded employee benefit plan (the Plan). Four months after subscribing to the Plan, she sought reimbursement for a coronary angioplasty and related medical treatment. …

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