ill analyze the reasoning that the U.S. Supreme Court provided for allowing such a high burden of proof for claimants in ERISA actions. II.Overview of the Employee Retirement Income Security Act and ProcedureERISA was designed to secure employee pensions and benefits for their future use by employees. Enacted in 1974, ERISA was a response to concerns about fraud and abuse within private employee benefit programs. See 29 U.S.C. 1001. ERISA established federal uniform duties and obligations for benefit plan administrators to ensure the preservation of employee pension funds and benefit plans. ERISA governs all benefit programs, which fall within the ERISA's statutory definition of "employee welfare benefit plans." ERISA defines "employee welfare benefit plan," as (1) any plan, fund, or program; (2) established or maintained by an employer; (3) through the purchase of insurance or otherwise; (4) for the purpose of providing medical, surgical, hospital care, sickness, disability, death or unemployment benefits; (5) to its participants and beneficiaries. 29 U.S.C. 1002. As long as a benefit plan falls within ERISA’s coverage, a plan participant may bring civil suit appealing their denied claim. See 29 U.S.C. 1132(a)(1)(B). A participant of a plan governed by ERISA may bring suit in three situations. First, a participant may bring suit to recover benefits due under the terms of the plan. Second, he or she may bring an action to enforce rights under the terms of the plan. Finally, a participant may bring suit to clarify his or her rights to future benefits under the terms of the plan. Firestone Tire & Rubber Co. v. Brunch, 489 U.S. 101, 109 S.Ct. 948, 103 L.Ed.2d 80 (1989). ERISA additionally includes procedural formalities that must be satisfied before a claimant may bring civil suit. First, the participant must file a written claim with the plan administrator. 29 U.S.C. 1002. If the claimant has not filed...
