Zaccone v. Standard Life Insurance Company (ND Ill)
May 01, 2013OUTCOME:
In the opinion from Zaccone v. Standard Life Insurance Company, the court holds that the US Supreme Court decision in Conkright v. Frommert does not nullify the Illinois statute prohibiting the inclusi ... on of discretionary language in health and welfare insurance policies and that state statutes banning discretionary language are not violative of congressional intent. The court holds that the Illinois statute is not preempted by ERISA. As a result, the court concludes that the de novo standard of review will apply. The May 1, 2013 memorandum and order is also available at 2013 U.S. Dist. LEXIS 62062. http://www.ddbchicago.com/files/2013/05/ECF_79_Memorandum_Opinion_and_Order_re_Standard_of_Review.pdf
