1. Whether , in this denial of benefits case under
the Employee Retirement Income Security Act of 1974
(ERISA), 29 U.S.C. §§ 1001 et seq. , the court of appeals
applied the wrong standard of judicial review under
Firestone Tire and Rubber Co. v. Bruch , 489 U.S. 101
(1989) in view of Conkright v. Fromm ert, 559 U.S. 506
(2010) , and deepened an established circuit split,
when the court :
a. extended the plan's grant of interpretive authority beyond p lan terms that are "clear and accurate" to even ambiguous terms that are not
ERISA- compliant , and concluded—by virtue of the
presum ed grant —that the plan administrator's interpretation of an ambiguous exclusionary provision was entitled to Firestone deference ; and
b. did not invoke the doctrine of contra
proferentem to resolve the ambiguous exclusionary
provision .

2. Does ERISA's "full and fair review" mandate
apply to each ground asserted in a plan administrator's final denial , such that a plan administrator
abus es its discretion in barring benefit recovery based
on a procedurally defective ground ?

Whether the court of appeals applied the wrong standard of judicial review under Firestone-Tire-and-Rubber-Co-v-Bruch