to the first prong of Darland’s holding was this Court’s conclusion that ERISA plan administrators are generally required, like the SSA, to give deference to the opinions of a claimant’s treating physician. That principle has since been rejected by the United States Supreme Court, however. In Black & Decker Disability Plan v. Nord, 538 U.S. 822, 123 S.Ct. 1965, 155 L.Ed.2d 1034 (2003), the Supreme Court held that, while plan administrators may not arbitrarily reject or refuse to consider the opinions of a treating physician, they “are not obligated to accord special deference to the opinions of treating physicians.” Id. at 825, 123 S.Ct. 1965. Thus, the “treating physician rale” followed in Darland no longer applies in the ERISA context. See also Whitaker, supra, 121 Fed. Appx. at 88 (<HOLDING>). This is not to say, however, as Liberty
holding that the district court is limited to considering the administrative record in reviewing the denial of benefits under an erisa plan holding that an employees claim against plan administrator for denied benefits is preempted holding that erisa does not preempt the plaintiffs claim that the erisa plan administrator is liable for medical malpractice where the plaintiff premised the claim solely on state law and did not invoke the erisa plan holding that district courts order remanding an erisa benefits determination to a plan administrator was nonfinal and therefore not appealable after the remand to plan administrator plan participant still could appeal the district courts decision that erisa preempted her state law claim and if successful she would be able to pursue punitive damage holding that an erisa plan administrator is not bound by an ssa disability determination when reviewing a claim for benefits