KEARNEY v. STANDARD INSURANCE COMPANY, 175 F.3d 1084 (9^th Cir. 1999) (en banc)-Court notes that although the policy said Kearney's law firm was the plan administrator, the parties assumed Standard was the plan administrator. Standard argued that a scrivener's error resulted in the law firm and not Standard being named the plan administrator. Ninth Circuit held that the language "upon receipt of satisfactory written proof that you have become DISABLED[.]" did not grant discretion. Thus, the de novo standard of review is appropriate. Court limited de novo review to the record before the plan administrator at the time of the denial. The Court reversed the summary judgment granted to Standard and determined that Kearney should get a trial. The Ninth Circuit created a novel form of trial-a trial on the administrative record.