In Scorzo v. Unum Life Insurance Company of America, No. 23-cv-3836, 2026 WL 2070002 (N.D. Ill. July 17, 2026), United States District Judge Jeffrey I. Cummings granted judgment to Unum and denied Plaintiff’s cross-motion, holding that Plaintiff, a former Starbucks store manager with multiple sclerosis, failed to prove by a preponderance of the evidence
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Seventh Circuit Affirms That ESOP Fiduciaries Did Not Breach Their Duties or Engage in a Prohibited Transaction in Approving the Sale of an ESOP-Owned Company
In Rush v. GreatBanc Trust Co., No. 25-1736, — F.4th —-, 2026 WL 2071139 (7th Cir. July 17, 2026), the Seventh Circuit affirmed a defense judgment entered after a three-week bench trial in a suit brought by a participant in the employee stock ownership plan that wholly owned Segerdahl Corporation, a direct-mail printing company.…
When “Sedentary” Isn’t the Whole Job: California Court Restores 20 Years of ERISA Disability Benefits Reliance Standard Cut Off
In Cyr v. Reliance Standard Life Insurance Company, No. 2:23-cv-06286-DSF-RAO, 2026 WL 2056667 (C.D. Cal. July 15, 2026), United States District Judge Dale S. Fischer, following a bench trial on the administrative record, found in favor of a long-term disability claimant whose ERISA benefits Reliance Standard Life Insurance Company had paid for two decades…
Third Circuit Revives Hospitals’ ERISA Underpayment Claims Against Cigna Under MRC-1 and MRC-2 Plans
In Hudson Hospital OPCO, LLC v. Cigna Health & Life Insurance Co., No. 24-2830, 2026 WL 2057076 (3d Cir. July 16, 2026), three New Jersey hospitals appealed the dismissal of claims they brought against Cigna Health and Life Insurance Company and Connecticut General Life Insurance Company under ERISA, alleging that the insurers underpaid them…
When Can an ERISA Claimant Get Discovery Beyond the Administrative Record? A New York Court Draws the Line
In De Mello v. First Unum Life Insurance Company, No. 25-cv-7933 (LJL), 2026 WL 2032059 (S.D.N.Y. July 14, 2026), United States District Judge Lewis J. Liman denied an ERISA long-term disability claimant’s motion to compel discovery into matters outside the administrative record. Plaintiff participates in an employee welfare benefit plan sponsored by his law…
Third Circuit Revives ERISA Recovery and Fiduciary-Breach Claims Tied to Cigna’s MRC-1 Out-of-Network Reimbursements
In Advanced Gynecology & Laparoscopy of North Jersey P.C. v. Cigna Health & Life Insurance Co., No. 24-2212, 2026 WL 2030368 (3d Cir. July 13, 2026), nearly two dozen New Jersey healthcare practices, providing out-of-network services to Cigna subscribers who had assigned their plan benefits, alleged that Cigna systematically underpaid them for thousands of…
Fifth Circuit Vacates and Remands ERISA Fiduciary-Breach Judgment for Failure to Make Necessary Causation Findings on Article III Standing
In Guenther v. BP Retirement Accumulation Plan, No. 24-20551, 2026 WL 2031828 (5th Cir. July 14, 2026) (per curiam), the United States Court of Appeals for the Fifth Circuit vacated a judgment entered in favor of a class of current and former BP employees on their ERISA fiduciary-breach claims and remanded for the district…
When Does an ERISA Complaint Fail? A New Jersey Court Dismisses Disability Benefits and Retaliation Claims
In Magdalasov v. ByteDance Inc., No. 25-13824 (ES) (JBC), 2026 WL 2017269 (D.N.J. July 13, 2026), the United States District Court for the District of New Jersey, per U.S. District Judge Esther Salas, granted the defendants’ motions to dismiss a pro se ERISA claimant’s short-term disability suit and to compel arbitration of his retaliation claim.…
Eighth Circuit Affirms Exclusion of Undisclosed Damages Auditor and Summary Judgment for Employer in ERISA Delinquent-Contribution Suit
In Board of Trustees of the Iron Workers St. Louis District Council Pension Fund Trust v. Barnhart Crane & Rigging Co., No. 25-1497, 2026 WL 2016237 (8th Cir. July 13, 2026), Union fund trustees and three affiliated local unions sued Barnhart Crane & Rigging Co. under ERISA and the Labor Management Relations Act, alleging…
Michigan Federal Court Reinstates ERISA Long-Term Disability Benefits After Insurer Applied the Wrong Plan Definition
In Fitzgerald v. Metropolitan Life Insurance Company, No. 23-13169, 2026 WL 1990460 (E.D. Mich. July 9, 2026), District Judge David M. Lawson granted judgment to a former automotive production worker whose ERISA-governed long-term disability benefits MetLife had terminated, holding that MetLife improperly denied the claim by applying the wrong plan definition of disability and…