Mealey's (January 14, 2022, 11:35 AM EST) -- NEW YORK — Concluding that there was no clear error in the factual findings and declining to apply a less deferential standard of review, the Second Circuit U.S. Court of Appeals in a Jan. 11 summary order affirmed the judgment of a New York federal court that dismissed a disability claimant’s suit under the Employee Retirement Income Security Act of 1974 following determination on the papers....