What is the standard of review for a long term disability plan administrator in a tort action?

MultiRegion, United States of America

The following excerpt is from Estate of Barton v. ADT Sec. Servs. Pension Plan, 820 F.3d 1060 (9th Cir. 2016):

In reviewing the plan administrator's decision in light of the administrative record, a court may not substitute [its] view for that of the factfinder. Salomaa, 642 F.3d at 676. Rather, the scope of review is limited: the court may consider only whether the plan administrator's decision was (1) illogical, (2) implausible, or (3) without support in inferences that may be drawn from the facts in the record. Id. This standard of review applies to the plan administrator's factual determinations as well as its ultimate decision. Walker v. American Home Shield Long Term Disability Plan, 180 F.3d 1065, 106970 (9th Cir.1999). Under deferential review, a district court considers only whether the claimant showed that the plan administrator's benefit decision was unreasonable,

[820 F.3d 1071]

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