Firestone Tire and Rubber Co. v. Bruch

In Firestone Tire and Rubber Co. v. Bruch, U.S. 109 S.Ct. 948, 103 L.Ed.2d 80 (1989), the Supreme Court held that a denial of benefits challenged under ERISA "is to be reviewed under a de novo standard unless the benefit plan gives the administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the terms of the plan." Id. at 956. In other words, unless the plan language specifies otherwise, courts should construe any disputed language "without deferring to either party's interpretation." See Id. at 955. If a plan does "not give the employer or administrator discretionary or final authority to construe uncertain terms," a reviewing court should review the employee's claims as it would "any other contract claim". See Id.