Doe v. Harvard Pilgrim Health Care Inc.
Petition for certiorari denied on May 24, 2021
Issues: (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.