051565P.pdf   03/23/2006  Sandra J. Chronister  v.  Baptist Health
   U.S. Court of Appeals Case No:  05-1565
                          and No:  05-1566
   Eastern District of Arkansas   
   [PUBLISHED] [Smith, Author, with Heaney and Benton, Circuit Judges] 
   Civil case - ERISA. Defendant's employee benefit plan was not exempt 
   from ERISA as a "church plan;" church plays no role in the governance 
   of the defendant hospital, does not provide any financial support and any 
   denominational requirement is limited to certain high level employees; 
   there was no financial conflict of interest present in the decision to deny 
   benefits, and a less deferential standard of review is not justified on that 
   ground; nor were there any procedural irregularities in the review process 
   which would justify imposition of a de novo standard of review; trigger- 
   point findings consistent with fibromyalgia constitute objective evidence 
   of the disease, and plaintiff's condition, since it was supported by 
   objective evidence, was not subject to the 24-month benefit cutoff 
   applied to conditions based on subjective claims with only self-reported 
   symptoms.