Blue Cross & Blue Shield of Alabama v. Brown

finding conflict of interest where Blue Cross, acting as administrator of an ERISA Plan, provided insurance coverage to the employer; paid all claims out of its own assets and suffered the losses; and made all eligibility determinations | less deference where claims decision made by insurer paying claims out of own assets | "[i]t is fundamental that the fiduciary’s interpretation first must be 'wrong' from the perspective of de novo review before a reviewing court is concerned with the self-interest of the fiduciary." | "The fiduciary duties section [of ERISA] [ ] requires adherence to the written plan documents unless their provisions conflict with statutory duties.... [cites omitted] One conflict might be identified between the contractual provision [at issue] [ ] and the standard of loyalty itself." | “when sentence A has expired but has been used to augment sentence B, the prisoner is “in custody” only on sentence B,” but the prisoner “may contend that that custody violates the Constitution if it was augmented because of an invalid sentence A” | "The fiduciary duties section [of ERISA] [ ] requires adherence to the written plan documents unless their provisions conflict with statutory duties.... [cites omitted] One conflict might be identified between the contractual provision [at issue] [ ] and the standard of loyalty itself.”