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Corey Wrenn, Individually and As Parent and Next Friend of S.W., A v. Principal Life Insurance Company; Principal Financial Group, Inc

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Submitted: September 23, 2010

Before BYE, BEAM, and SMITH, Circuit Judges.

Corey Wrenn appeals an order granting judgment in favor of Principal Life Insurance Company and Principal Financial Group, Inc. (collectively Principal) on Wrenn’s claim for medical benefits under a plan governed by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. §§ 1001-1461. Reviewing the denial of benefits for an abuse of discretion, the district court upheld Principal’s decision. Wrenn contends the district court should have reviewed Principal’s decision under a de novo standard because of procedural irregularities in the handling of the claim; in the alternative, Wrenn argues Principal’s denial was unreasonable and should be reversed even under the more deferential abuse-of-discretion standard. We agree with this latter argument, and therefore reverse.

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