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Sentencing Guidelines Interpretation Issue, and ERISA Matter

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By FindLaw Staff on May 12, 2010 1:33 PM

US v. Brown, No. 09-2296, concerned defendant's appeal following the district court's grant of his motion for a reduction in sentence pursuant to 18 U.S.C. section 3582(c)(2) and the 2008 Guidelines amendments, which retroactively reduced base offense levels for particular offenses involving cocaine base.  The court of appeals affirmed on the ground that, in section 3582(c)(2) proceedings, a district court lacks authority to reduce a defendant's sentence below the amended Guidelines range, and such proceedings did not constitute a full resentencing of the defendant.

Manning v. Am. Repub. Ins. Co., No. 09-2625, involved an ERISA action challenging the denial of plaintiff's short-term disability benefits.  The court of appeals affirmed summary judgment for defendant on the grounds that 1) the language of the plan defined who was an Approved Health Care Provider, and a physician assistant was not an Approved Health Care Provider; 2) defendant reasonably denied plaintiff's claim for insufficient evidence of a medically certified health condition; and 3) defendant's interpretation of the plan requiring objective medical evidence did not constitute a procedural irregularity and did not trigger a less deferential standard of review.

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