In Noelle E. v. Cigna Health & Life Ins. Co., 2:23-cv-00686, 2025 WL 754031 (D. Utah Mar. 10, 2025), in a medical benefits action brought under the Employee Retirement Income Security Act of 1974 (“ERISA”), Utah District Judge Howard C. Nielson Jr. granted Plaintiffs’ motion to complete the administrative record with materials related to
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Fifth Circuit Finds State Law Claims for Underpaid Pension Benefits Preempted by ERISA
In Broussard v. Exxon Mobil Corporation, No. 24-30664, 2025 WL 754536 (5th Cir. Mar. 10, 2025), a dispute alleging underpayment of pension benefits, the Fifth Circuit Court of Appeals considered whether the plaintiff’s state law claims are preempted by ERISA. Broussard, a former employee of ExxonMobil, had filed a lawsuit in Louisiana state court…
Fifth Circuit Cements Victory to AT&T in ERISA Dispute Seeking Statutory Penalties for Failing to Produce Documents
In Jones, IV, as executor & administrator of The Succession of Connie Porter Jones Marable v. AT&T, Inc., et al., No. 24-30187, 2025 WL 720939 (5th Cir. Mar. 6, 2025), the Fifth Circuit Court of Appeals reviewed the district court’s decision concerning whether AT&T owed discretionary penalties under ERISA for allegedly failing to provide…
District Court Awards Attorney’s Fees to ERISA Plaintiff, Highlighting Insurer’s Procedural Errors in Benefit Denial as Factor in Award
In Mullins v. The Consol Energy, Inc. Long Term Disability Plan, No. 2:20-CV-1883, 2025 WL 712931 (W.D. Pa. Mar. 5, 2025), Pennsylvania Western District Judge J. Nicholas Ranjan granted Plaintiff’s Motion for Attorney’s Fees in his action for recovery of long-term disability benefits pursuant to the Employee Retirement Income Security Act of 1974 (ERISA).…
Eleventh Circuit Affirms Denial of ERISA-Governed Short Term Disability Benefits, Finding Administrator’s Decision Was Not Arbitrary and Capricious
In Rubin v. Life Insurance Company of North America, et al., No. 24-10433, 2025 WL 689691 (11th Cir. Mar. 4, 2025), the Eleventh Circuit Court of Appeals upheld Life Insurance Company of North America’s (“LINA”) denial of Plaintiff Deborah Rubin’s short-term disability benefits, finding that the Magistrate Judge correctly granted summary judgment to LINA…
Eighth Circuit Affirms Award of Deferred Compensation Plan Benefits to Former Company Executive
In Hankins v. Crain Auto. Holdings, LLC, No. 24-1555, __F.4th__, 2025 WL 649895 (8th Cir. Feb. 28, 2025), the court affirmed the district court’s ruling in favor of Plaintiff-Appellee Barton Hankins in a dispute against his former employer, Crain Automotive Holdings, LLC. The case centered around Hankins’s claim for benefits under a deferred compensation…
Second Circuit Revives ERISA Breach of Fiduciary Duty Claims After Finding Pension Plan Participant Has Article III Standing
In Cudjoe v. Building Industry Electrical Contractors Association, et al., No. 24-921, 2025 WL 655580 (2d Cir. Feb. 28, 2025), a case alleging fiduciary misconduct involving the mismanagement of benefit fund assets, the Second Circuit determined that at the motion to dismiss stage, Plaintiff-Appellant Martin Cudjoe’s allegations of financial harm were sufficient to establish…
In Life Insurance Dispute, District Court Dismisses ERISA Claims Against Insurer and Allows Fiduciary Breach Claim Against Employer
In Butler v. Hartford Life & Accident Ins. Co., et al., No. 0:23-CV-3144 (KMM/DJF), 2025 WL 580892 (D. Minn. Feb. 21, 2025), Minnesota District Judge Katherine Menendez granted Defendant Hartford Life & Accident Insurance Company’s Motion to Dismiss, and both granted in part and denied in part Defendant employer CBIZ, Inc.’s Motion to Dismiss…
Ninth Circuit Upholds Determination that State Law Claims for Disability Insurance Benefits Are Preempted by ERISA
In Steigleman v. Symetra Life Insurance Company, No. 23-4082, 2025 WL 602175 (9th Cir. Feb. 25, 2025), the Ninth Circuit delved into the complexities of ERISA preemption and the criteria for establishing an employee welfare benefit plan. This case, on its second trip to the Ninth Circuit, sheds light on the nuanced processes involved…
District Court Dismisses ERISA Claims, Highlights Plaintiff’s Failure to Allege Entitlement to Prejudgment Interest, Tax Withholdings, Penalties or Equitable Relief
In Metaxas v. Gateway Bank F.S.B, et al., No. 20-CV-01184-EMC, 2025 WL 550749 (N.D. Cal. Feb. 19, 2025), California Northern District Judge Edward M. Chen granted Defendants’ Motion to Dismiss Plaintiff’s First Amended Supplemental Complaint alleging supplemental claims for tax withholdings, prejudgment interest, equitable relief and penalties, finding that the only remaining claim available…