"A Rhode Island federal court held an ERISA plan administrator did not act arbitrarily and capriciously when it denied disability benefits to an employee with depression, because she was being treated by a psychologist, rather than a psychiatrist, and failed to provide sufficient evidence of a disability." Vukic v. Melville Corp., 39 F. Supp. 2d 163 (D.R.I. Mar. 25, 1999). [MPDLR, May June 1999, 23:3:411]