The 9th Circuit Court of Appeals has reversed a lower-court ERISA-related decision that upheld a fiduciary's benefit denial in a ruling that could reach into other areas of benefit law.

At issue was the denial of benefits to a Wells Fargo & Co. employee who was admitted to Pacific Shores Hospital in California severely underweight, with anorexia, and was potentially suicidal. The 83-pound patient not only required close monitoring because of her physical condition but also because of her mental state.

Wells Fargo has a self-funded health plan under which the patient was covered. The plan allows Wells Fargo to determine benefits and to delegate its discretionary authority over benefits to claims administrators.

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