Torres V. Pittston Company

The only issue that we will definitively resolve in this appeal is the appropriate standard for a district court's review where an ERISA fiduciary, which is operating under a conflict of interest, denies disability benefits based on its determination of the factual circumstances of the beneficiary's claim The district court applied the deferential arbitrary-and-capricious standard of review, apparently adopting the argument of the Insurers *fn2 that the "insurer conflict rule" and its "heightened arbitrary capricious" standard of review should apply only to a fiduciary's decisions regarding plan interpretation, not to its factual determinations, even though the fiduciary is under a conflict of interest. We disagree, and accordingly reverse and remand for reconsideration under the appropriate standard of review.