In ERISA Litigation episode 005, Bentley Tolk (Parr Brown Gee & Loveless, Salt Lake City, UT) examines the U.S. Supreme Court’s April 21, 2010 Conkright v. Frommert decision. The Conkright decision is significant for its clarification of the standard of review under ERISA when a plan administrator makes an “honest” mistake in interpreting the plan. According to the Supreme Court, one “honest” mistake in interpreting a plan is not enough to strip a plan administrator of deference for subsequent related interpretations of the plan.