In Liggett v. Principal Financial Group, No. 22-CV-11183, 2025 WL 275119 (E.D. Mich. Jan. 23, 2025), Michigan Eastern District Judge Sean F. Cox conducted a nuanced exploration of the standards and processes required in disability claims adjudication, particularly focusing on the arbitrary and capricious standard of review, and ultimately granted judgment to Plaintiff on his
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District Court Grants Judgment to ERISA Claimant, Criticizing Insurer’s Arbitrary Denial of Long-Term Disability Benefits
In Berg v. The Lincoln National Life Insurance Company, No. 2:24-CV-00097-SAB, 2025 WL 252481 (E.D. Wash. Jan. 21, 2025), Washington Eastern District Judge Stanley A. Bastian granted judgment to Plaintiff Barbara Berg, a former Walmart employee, against The Lincoln National Life Insurance Company (“Lincoln”). In reviewing Lincoln’s denial of Berg’s long-term disability (LTD) benefits…
District Court Dismisses Lawsuit for Long-Term Disability Benefits Under ERISA Due to Claimant Filing Suit Too Soon
In Frederick v. Life Insurance Company of North America, No. 4:24-CV-00367-SRC, 2025 WL 71864 (E.D. Mo. Jan. 10, 2025), Missouri Eastern District Chief Judge Stephen R. Clark examined the contentious exhaustion of remedies issue in Plaintiff’s claim for long-term disability (“LTD”) benefits under a plan governed by the Employee Retirement Income Security Act (ERISA). The…
Sixth Circuit Finds Employer Is Not Liable under ERISA for Erroneous Benefit Statement Promising Greater Amount of Disability Insurance Benefits
In Higgins v. Lincoln Electric Company, Inc., No. 23-5862, 2025 WL 213846 (6th Cir. Jan. 16, 2025), the court addressed an ERISA-estoppel claim, focusing on the discrepancy between the long-term disability (LTD) benefits promised to Plaintiff-Appellant Jerry Higgins and the benefits he ultimately received based on a cap in the governing disability plan document.…
Seventh Circuit Affirms ERISA Fund’s Denial of Out-of-Network Medical Treatment
In Est. of Gifford v. Operating Eng’rs 139 Health Benefit Fund, No. 23-3356, __F.4th__, 2025 WL 79102 (7th Cir. Jan. 13, 2025), the Seventh Circuit Court of Appeals affirmed the district court’s decision to uphold the denial of insurance benefits for medical treatment received by a beneficiary of the Operating Engineers 139 Health Benefit…
Second Circuit Upholds Dismissal of ERISA Record-Keeping Fees Lawsuit
In Boyette v. Montefiore Med. Ctr., No. 24-1279-CV, 2025 WL 48108 (2d Cir. Jan. 8, 2025), decided by Circuit Judges Kearse, Raggi, and Lohier, Jr., the court upheld the dismissal of ERISA breach of fiduciary duty claims. Plaintiffs-Appellants, Sheila Boyette and Tiffany Jiminez, were former employees of Montefiore Medical Center and participants in its…
Tenth Circuit: Unum’s Termination of Long-Term Disability Benefits Was Not An Abuse of Discretion
In an unpublished decision, Isbell v. Unum Life Insurance Company of America, No. 23-1351, 2025 WL 40379 (10th Cir. Jan. 7, 2025), the Tenth Circuit Court of Appeals upheld Unum Life Insurance Company of America’s decision to terminate ERISA-governed long-term disability (LTD) benefits for Plaintiff-Appellant Isbell, a former store manager for Yankee Candle. Unum…
District Court Overturns Prudential’s Denial of Long-Term Disability Benefits under Employer Plan Based on Well-Documented Evidence from Treating Providers Supporting Total Disability
In Przybyla v. The Prudential Insurance Company of America, No. 3:24-CV-01090-JSC, 2025 WL 28446 (N.D. Cal. Jan. 3, 2025), on Rule 52 cross-motions for judgment, California Northern District Judge Jacqueline Scott Corley granted judgment in favor of Plaintiff finding that she had satisfied her burden of demonstrating “total disability” under her employer-sponsored ERISA long-term…
Eleventh Circuit Affirms Hartford’s Termination of Long-Term Disability Benefits
In Flowers v. Hartford Life & Accident Ins. Co., No. 23-7259, 2025 WL 33236 (2d Cir. Jan. 6, 2025), involving a dispute over long-term disability benefits (“LTD”), the Second Circuit affirmed the district court’s grant of summary judgment in favor of Hartford Life & Accident Insurance Company, thereby upholding the denial of continuing LTD…
District Court Dismisses ERISA And Non-ERISA Claims for Disability Benefits Finding That ERISA Coverage Had Terminated and Plaintiff’s Other Claims Were Preempted, Time-Barred or Not Viable
In Diederichs v. FCA US LLC, No. 23-CV-11287, 2024 WL 5168087 (E.D. Mich. Dec. 19, 2024), Michigan Eastern District Judge Robert J. White adopted the Magistrate Judge’s report and recommendations granting Defendant’s motion to dismiss Plaintiff’s action seeking disability benefits under the employer’s Disability Assistance Program (“DAP”) followed by long-term disability (“LTD”) benefits, and…