In England v. DENSO Int’l Am. Inc., No. 24-1360, —F.4th—-, 2025 WL 1300923 (6th Cir. May 6, 2025), the Sixth Circuit affirmed the dismissal of a putative class action alleging that DENSO’s 401(k) plan fiduciaries breached their duty of prudence under ERISA by overpaying for recordkeeping and administrative services. The plaintiffs argued that the
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District Court Finds MetLife Improperly Terminated LTD Benefits Overly Relying on Selective Medical Reviews and Surveillance Footage
By Kristin Kyle
In LaLonde v. Metropolitan Life Insurance Company, No. 24-CV-01781-DSF-MBK, 2025 WL 1324139 (C.D. Cal. May 8, 2025), after a court trial on the administrative record, California Central District Judge Dale S. Fischer found that Plaintiff had demonstrated by a preponderance of the evidence his continued entitlement to long-term disability (“LTD”) benefits, under an ERISA-governed…
Fifth Circuit Affirms Dismissal of ERISA Breach of Fiduciary Duty Claim, Underscoring Plan Participants’ Duty to Inform Themselves of Plan Provisions
In LeBoeuf v. Entergy Corporation, et al., No. 24-30583, 2025 WL 1262414 (5th Cir. May 1, 2025), the Fifth Circuit Court of Appeals affirmed the district court’s dismissal of a breach of fiduciary duty claim under ERISA, brought by the Appellants, the children of decedent Alvin Martinez, against Entergy Corporation, its Employee Benefits Committee,…
District Court Finds Reliance Standard Did Not Abuse Its Discretion in Applying 24-Month Mental Illness Limitation in Traumatic Brain Injury Claim
By Kristin Kyle
In Hall v. Reliance Standard Insurance Company, No. CV 23-20761 (ZNQ) (RLS), 2025 WL 1233203 (D.N.J. Apr. 29, 2025), on cross-motions for summary judgment, New Jersey District Judge Zahid N. Quirashi granted judgment in favor of Defendant Reliance Standard Insurance Company, finding that Reliance had not abused its discretion in terminating benefits after 24 months…
Second Circuit Holds that Special Financial Assistance Program Does Not Per Se Exclude Multiemployer Pension Plans Previously Terminated by Mass Withdrawal
In Bd. of Trs. of Bakery Drivers Loc. 550 & Indus. Pension Fund v. Pension Benefit Guar. Corp., No. 23-7868, –F.4th—-, 2025 WL 1226844 (2d Cir. Apr. 29, 2025), the Second Circuit considered a dispute over eligibility for the Special Financial Assistance (SFA) program created under the American Rescue Plan Act of 2021. The…
District Court Orders Guardian to Include Claimant’s K-1 Earnings in Calculation of Long-Term Disability Benefits
By Kristin Kyle
In Rappaport v. Guardian Life Insurance Company of America, No. 1:22-CV-08100 (JLR), 2025 WL 1156760 (S.D.N.Y. Apr. 21, 2025), New York Southern District Judge Jennifer L. Rochon granted judgment in favor of Plaintiff on his claim for recovery of unpaid ERISA-governed long-term disability (“LTD”) benefits. In a bench trial, the court addressed whether the LTD…
Seventh Circuit Affirms District Court Decision Holding that Employers’ post-2014 Contribution Rate Increases Should be Excluded from Withdrawal Liability Obligations
In Cent. States, Se. & Sw. Areas Pension Fund v. Event Media Inc., No. 24-1739, 2025 WL 1185368 (7th Cir. Apr. 24, 2025), the Seventh Circuit addressed a statutory interpretation issue concerning the calculation of withdrawal liability for employers withdrawing from multiemployer pension plans. The court affirmed the district court’s ruling that certain post-2014…
Fifth Circuit Affirms Insured Substantially Complied with Life Insurance Policy’s Change-of-Beneficiary Requirements
In Morgan, et al. v. Barrera, et al., No. 21-20497, 2025 WL 1157549 (5th Cir. Apr. 21, 2025), a dispute over life insurance benefits under an ERISA-governed plan, the Fifth Circuit Court of Appeals addressed two primary legal issues: standing under ERISA and the doctrine of substantial compliance.
Janie Barrera worked for Walgreens and…
U.S. Supreme Court Holds Unanimously that ERISA Plaintiffs Need Only Plausibly Allege Elements of Prohibited-Transaction Claim Without Addressing Affirmative Defenses
In Cunningham v. Cornell Univ., No. 23-1007, —S.Ct.—-, 2025 WL 1128943 (U.S. Apr. 17, 2025), the U.S. Supreme Court addressed the pleading standards for claims under the Employee Retirement Income Security Act of 1974 (ERISA), specifically focusing on prohibited transaction claims under 29 U.S.C. § 1106(a)(1)(C). The Court’s decision, delivered by Justice Sonia Sotomayor,…
District Court Upholds Unum’s Denial of LTD Benefits Highlighting Evidentiary Requirements in Subjective Symptom ERISA Claims
By Kristin Kyle
In Stickley v. Unum Life Insurance Company of America, No. 3:24-CV-05364-TMC, 2025 WL 1094346 (W.D. Wash. Apr. 10, 2025), Washington Western District Judge Tiffany M. Cartwright granted Unum’s motion for judgment and denied Plaintiff’s cross-motion for judgment and motion to supplement the administrative record, finding that Plaintiff failed to demonstrate entitlement to long-term disability (“LTD”)…