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Timeline of major ERISA decisions made by the federal courts
1989In Firestone Tire and Rubber Co. vs. Bruch, the U.S. Supreme Court rules that federal courts should review the denial of ERISA health plan benefits only for arbitrariness and capriciousness, as long as the plan explicitly grants discretionary authority to make benefit decisions to a plan administrator or another fiduciary.
1990In Baker vs. Big Star Division of the Grand Union Co., the 11th U.S. Circuit Court of Appeals rules that to qualify for judicial deference under the Firestone standard, an ERISA plan administrator that delegates its claims-handling authority must do so only to other fiduciaries.
1990In Madden vs. ITT Long Term Disability Plan for Salaried Employees, the 9th Circuit rules that plan decisions qualify for judicial deference when a fiduciary delegates its discretionary authority to another fiduciary. Both fiduciaries would qualify for judicial deference. The 10th Circuit in a later ruling would call this decision "ambiguous."
2006In Geddes et al. vs. United Staffing Alliance Employee Medical Plan et al., the 10th Circuit rules that judicial deference extends to the benefit decisions made by properly designated nonfiduciaries, such as third-party claims administrators.