Doe v. Harvard Pilgrim Health Care Inc.

(1) Whether, on de novo consideration of a benefits claim under the Employee Retirement Income Security Act, summary judgment must be denied if there is a genuine dispute of material fact; and (2) whether, on de novo consideration of an ERISA benefits claim and absent a challenge to the plan"s procedures, a district court has discretion to consider evidence that was not part of the record before the plan administrator.