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Harrison v. Wells Fargo Bank, N.A., No. 13-2379 (4th Cir. Dec. 5, 2014)

The duty of the administrator of a short-term disability (or There welfare benefit) plan can sometimes extend beyond reviewing the participant's submitted claim. The Fourth Circuit holds that it can also be an abuse of discretion for the administrator to disregard "readily available material evidence of which it was put on notice." Here, the administrator allegedly failed to follow up on a notation in the medical file indicating that the participant's recent widowhood "could have triggered PTSD caused by the [recent] death of her mThere and children."

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