October Term 2002 · Docket 02-469

Must ERISA plans accept treating physician opinions over other medical evidence?

the sides that brought the case argue the Ninth Circuit wrongly forces plans to accept treating physician views. the opposing sides claim this rule protects disabled workers from biased denials.

Official caption
Black & Decker Disability Plan v. Nord
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Verified source milestones

  1. — An official oral-argument transcript was verified.
  2. — An official oral-argument transcript was verified.

The arguments, in order

This case may have been argued more than once. Each entry below uses that session's official transcript. Later arguments do not erase earlier ones.

  1. Argument 1 ·

    What happened at the argument

    Mr. Rohlfing argued lower courts confused conflict of interest with actual bias. He stated this confusion occurred after the Firestone decision. He claimed this misinterpretation harms plan administrators.

    Mr. Paterson argued the Ninth Circuit rule is categorical. He stated it assumes treating physician opinions are superior. He claimed this assumption lacks support in the record.

    Ms. Blatt stated the Secretary did not impose a treating physician requirement. She argued the Secretary did not constrain plan administrators. She maintained the Secretary considered alternatives to this rule.

    Read the official transcript for this argument · Official argument details

    Sources used for this argument breakdown

A citizen's guide to the whole case

What this case is about

This case tests whether federal disability plans must prioritize treating physician opinions. The Ninth Circuit created a rule requiring plans to accept these views or provide specific reasons for rejection. the sides that brought the case argue this rule misinterprets federal law. the opposing sides argue it prevents arbitrary denials of benefits.

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How the case got here

The Supreme Court heard oral argument in this case on April 28, 2003.

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What each side wants

the sides that brought the case want the Court to strike down the treating physician rule. They argue this rule wrongly constrains plan administrators. They seek a standard that allows flexible review of medical evidence.

the opposing sides want the Court to keep the treating physician rule. They argue this rule protects disabled workers. They seek a standard that prevents arbitrary benefit denials.

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What each side says

the sides that brought the case argue the Ninth Circuit rule creates a categorical presumption. They claim this presumes treating physician opinions are superior. They argue this conflicts with federal law principles.

the opposing sides argue the rule requires specific legitimate reasons for rejection. They claim this prevents arbitrary denials of benefits. They argue this protects workers from biased plan administrators.

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What the justices asked

Justice Scalia asked about conflict of interest. He questioned if lower courts confused conflict with actual bias. the sides that brought the case argued lower courts grossly confused these concepts.

Justice O'Connor asked if the Secretary considered alternatives. She questioned if the Secretary imposed a treating physician requirement. the opposing sides stated the Secretary did not impose such a requirement.

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Why it matters

This case defines how disability plans review medical evidence. It determines whether plans must prioritize treating physician opinions. It affects the rights of workers seeking disability benefits. It shapes the balance between plan flexibility and worker protection.

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What happens next

This article currently covers the argument record. Use the official docket link for later case activity.

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Official Court provenance

Official docket and case history · Official Supreme Court oral-argument detail page

Title and summary sources

Revision history

  1. Revision 1 · Official Transcript ·

    Correction: Rewritten to the concise citizen-facing editorial standard.

  2. Revision 2 · Official Transcript ·

    Correction: Migrated to the dated official Court activity contract without model use.

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