Eighth Circuit: Theodore Ingram v. Terminal Railroad Association

ERISA

Where additional evidence is admitted during the proceedings, a court can retain the abuse of discretion standard by making its decision from the administrative record.

Administrator's characterization of relocation expenses was reasonable.

District court did not abuse discretion in finding that Administrator's offset of prior plan's benefits for  full vesting -as opposed to the actual early retirement payments - was reasonable.

http://media.ca8.uscourts.gov/opndir/16/01/143589P.pdf