Case Citator › Woo v. Deluxe Corp.

Woo v. Deluxe Corp.

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Eighth Circuit
Citation
144 F.3d 1157
Decided
Confirmed treatments
2
Flagged citations read
34 of 34
Citing cases (total)
34
Treatment dates
2008–2020
Overruled in part
A reviewed court has overruled part of this case’s holding. Woo v. Deluxe Corp. was overruled in part on review of benefit decisions by a financially conflicted ERISA plan administrator. Metropolitan Life Insurance Co. v. Glenn requires courts to weigh that conflict as one factor under abuse of discretion review; the Eighth Circuit recognized Glenn's partial abrogation of Woo in Boyd v. ConAgra Foods, Inc. and Ruessler v. Boilermaker-Blacksmith National Pension Trust.
More on how this was screened

The Eighth Circuit later questioned whether Woo's separate procedural irregularity rule also survives, but has left that issue open. All 34 flagged citations have been read; the 2 confirmed treatments are listed below.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

34 later cases cite Woo v. Deluxe Corp.; 34 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Woo v. Deluxe Corp.?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in part

  • The Supreme Court displaced Woo's rule that an insurer's financial conflict can trigger a less deferential sliding scale of review.

    Metropolitan Life Insurance Co. v. Glenn · Supreme Court of the United States · filed

    We here decide that this dual role creates a conflict of interest; that a reviewing court should consider that conflict as a factor in determining whether the plan administrator has abused its discretion in denying benefits; and that the significance of the factor will depend upon the circumstances of the particular case.
    Read the full opinion on CourtListener →

Questioned

  • The Eighth Circuit doubted whether Woo's sliding scale survives even for procedural irregularities, while leaving that question unresolved.

    McIntyre v. Reliance Standard Life Insurance Co. · Eighth Circuit · filed

    There is reason to doubt Woo’s sliding scale approach survived Glenn in any respect.
    Read the full opinion on CourtListener →

Does this case still carry your argument?

Describe your facts. Ezel reads Woo v. Deluxe Corp. and the cases that treated it, then tells you whether it still holds for your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace