Law360, New York (March 11, 2014, 6:36 PM EDT) -- In Cozzie v. Metropolitan Life Insurance Co. (7th Cir. 1998), a case involving the denial of accidental death benefits contained in a life insurance policy governed by the Employee Retirement Income Security Act of 1974, the Seventh Circuit, reviewing a district court's ruling under the arbitrary and capricious standard of review, infamously stated that while the plan administrator's decision under that standard of review is due "extreme deference," that review was not without some teeth. Furthermore, the Seventh Circuit stated that the reviewing court should not merely rubber stamp plan administrators' decisions that run contrary to the plain meaning of a disability plan — language that has haunted the decisions of ERISA plan and claims administrators ever since, both in the Seventh Circuit and in others that adopted Cozzie's reasoning....