RONALD LEE GILMAN, Circuit Judge. Three years prior to filing for Chapter 7 bankruptcy relief, Michael and Christina Nowak executed a mortgage on their residence in favor of PCFS Financial. Lydia Spragin, the trustee of the Nowaks’ bankruptcy estate, successfully voided PCFS’s lien on the residence based on a technical defect in the execution of the mortgage instrument. After losing its secured-creditor status, PCFS failed to file a formal proof of claim with the bankruptcy court. Spragin’s final report to the bankruptcy court, therefore, did not propose any distribution to PCFS from the bankruptcy estate. PCFS objected to the report and moved the court to allow an informal proof of claim based on PCFS’s prior filings as a putative secured creditor.

The bankruptcy court denied the motion, concluding that PCFS’s prior filings did not constitute an informal proof of claim. In the alternative, the court determined that the equities did not favor PCFS even if the prior filings were deemed to meet the informal-proof criteria. On appeal, the Bankruptcy Appellate Panel (BAP) disagreed with the bankruptcy court’s first conclusion, but affirmed on the basis that the court’s alternative conclusion regarding the equities was not an abuse of discretion. For the reasons set forth below, we AFFIRM the judgment of both the BAP and the bankruptcy court.

RONALD LEE GILMAN, Circuit Judge. On November 7, 2005, Thomas Kovach was riding his motorcycle while intoxicated, ran a stop sign, and collided with another vehicle in the intersection. He sustained severe injuries that led to the amputation of his left leg below the knee. Mr. Kovach was insured under an accidental death and dismemberment (AD&D) insurance policy provided by his wife’s employer (hereafter referred to as the Plan). He and his wife Rebecca filed a claim with Zurich American Insurance Company, the administrator of the Plan, for dismemberment benefits. Zurich denied the Kovaches’ claim after determining that Mr. Kovach’s injuries were caused by his drunk driving and therefore not covered as an “accidental” occurrence under the Plan.

The Kovaches brought a claim under the Employee Retirement Income Security Act, 29 U.S.C. §§ 1001-1461 (ERISA), that challenged Zurich’s denial of coverage. Applying a deferential arbitrary-and-capricious standard, the district court granted summary judgment in favor of Zurich. On appeal, the Kovaches argue that (1) the district court should have applied a de novo standard of review because Zurich improperly delegated its decisionmaking authority to an outside lawyer, and (2) Zurich’s denial of their claim was improper under either standard. Although we reject the Kovaches’ first argument, we agree with their second. We therefore REVERSE the judgment of the district court and REMAND the case for the entry of a judgment in favor of the Kovaches.

CLAY, Circuit Judge. Petitioner William Johnson (“Johnson”) appeals the district court’s judgment denying his petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2254. On appeal, he argues that the state violated his Sixth Amendment right to a public trial when it excluded the public fromthe courtroom during portions of his jury trial and that his Sixth Amendment right to effective assistance of counsel was violated when his trial attorney failed to object to the closure. For the reasons that follow, we VACATE the judgment of the district court and REMAND for an evidentiary hearing.