By: Derek Hawkins//September 8, 2015//
Civil
7th Circuit Court of Appeals
Officials: BAUER, KANNE, and HAMILTON, Circuit Judges.
ERISA – Standard of Review
No.14-1984 Mary C. Fontaine v. Metropolitan Life Insurance Company
Illinois insurance regulation prohibiting discretionary clauses not preempted by ERISA.
“MetLife’s final argument is that § 2001.3 does not prohibit all discretionary clauses but only clauses reserving discretion “to interpret the terms of the contract, or to provide standards of interpretation or review that are inconsistent with the laws of this State.” MetLife claims that clauses reserving discretion to make benefit determinations are unaffected by § 2001.3. In Firestone, the Supreme Court rejected this artificial dichotomy between “benefit determinations” and “contract interpretation,” pointing out that “the validity of a claim to benefits under an ERISA plan is likely to turn on the interpretation of terms in the plan at issue.” 489 U.S. at 115. MetLife does not grapple with this point, much less argue that this is an exceptional case where its benefit determination did not “turn on the interpretation of terms in the plan at issue.” Id”
Affirmed