Schatz v. Mutual of Omaha Insur. Co., 220 F.3d 944 (8^th Cir. 2000)-This court affirmed the district court's summary judgment against Schatz in her claim for long-term disability benefits. The court determined that the medical evidence provided by Schatz’ physicians was not consistent or conclusive, and found that Mutual of Omaha’s decision was not arbitrary and capricious.  On the question of standard of review, this court conceded that Mutual's role as both plan administrator and insurer satisfied the first prong of the Woo conflict of interest test. See Woo v. Deluxe Corp., 144 F.3d 1157, 1160 (8^th Cir. 1998) (quoting Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 115 (1989)). See detailed analysis. However, Schatz failed to demonstrate the second prong of that test—that the "palpable conflict of interest" caused a serious breach of the plan administrator's fiduciary duty. The court found that Schatz failed to show such causation when she did not present sufficient evidence that Mutual of Omaha made the decision without proper judgment, or the decision was "the product of an arbitrary decision or the plan administrator's whim."

This court did not address whether such a formulation of the causation blends arbitrary and capricious review into the conflict of interest determination. It did, however, state in a footnote the reverse—that "a failure to satisfy the Woo gateway requirement to less deferential review [i.e. causation] may strongly suggest that a plan administrator's decision was not arbitrary and capricious." See Barnhart v. UNUM Life Ins. Co., 179 F.3d 583, 588 (8^th Cir. 1999). See detailed analysis.