(March 12, 2020, 12:27 PM EDT) -- BOSTON — Clear error review in an Employee Retirement Income Security Act mental health benefits case requires an evidentiary hearing to ensure that the court does not erroneously read the record as a judge did in determining that residential treatments were not medically necessary in the absence of acute symptoms, a woman said in March 9 briefing to the First Circuit U.S. Court of Appeals (Jane Doe v. Harvard Pilgrim Health Care Inc., et al., No. 19-1879, 1st Cir.)....