In Lifecare Management Services LLC v. Insurance Management Administrators Inc., 2013 U.S. App. LEXIS 239 (5th Cir. Jan. 4, 2013), the Fifth Circuit affirmed the district court’s ruling that a third party administrator of an ERISA welfare plan was a proper defendant in a claim for benefits under ERISA § 502(a)(1)(B) if the TPA “exercise[d] ‘actual control’ over the benefits claim process.” Here, the TPA had been delegated the power to deny benefit claims filed by participants of the plan and the Court determined it abused its discretion by incorrectly interpreting plan language.