In Kirsten W. v. California Physicians’ Service, No. 25-4029, 2026 WL 1433128 (10th Cir. May 21, 2026), the Tenth Circuit dismissed an appeal from an ERISA mental-health benefits dispute, concluding in an unpublished order and judgment that the district court’s grant of summary judgment was not a “final decision” under 28 U.S.C. § 1291
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Supreme Court Holds ERISA Permits Multiemployer Pension Plans to Use Actuarial Assumptions Adopted After the Measurement Date in Calculating Withdrawal Liability
In M & K Employee Solutions, LLC v. Trustees of the IAM National Pension Fund, No. 23-1209, ___ S.Ct. ___, 2026 WL 1423319 (U.S. May 21, 2026), a unanimous decision authored by Justice Jackson, the Supreme Court resolved a circuit split over when actuaries must select the assumptions used to calculate an employer’s withdrawal…
When “We Settled” Means Settled: Eastern District of Tennessee Enforces Mediated ERISA Settlement and Awards Unum Its Fees
In Williams v. Unum Life Insurance Company of America, No. 1:25-cv-61, 2026 WL 1412607 (E.D. Tenn. May 19, 2026), United States District Judge Curtis L. Collier granted Unum’s motion to enforce a settlement agreement reached at mediation and awarded Unum its attorney fees incurred in pursuing enforcement. The decision is a sharp reminder that,…
Second Circuit Affirms Dismissal of Out-of-Network Provider’s ERISA Claim Where Provider Failed to Establish Beneficiary Status or Valid Assignment and Abandoned Claim on Appeal
In Emsurgcare, Emergency Surgical Assistant v. Hager, No. 25-1975-CV, 2026 WL 1378672 (2d Cir. May 18, 2026), Plaintiffs-Appellants Emsurgcare and Emergency Surgical Assistant (together, “Emsurgcare”) provided emergency surgical services to Plaintiff in 2018 at a Los Angeles hospital. Emsurgcare billed Oxford Health Plans (NY), Inc. and Oxford Health Insurance (together, “Oxford”) $103,500 for those…
When Interpleader Serves the Insurer More Than the Beneficiary: Court Denies MetLife Fees in ERISA Life Insurance Dispute
In Metropolitan Life Insurance Company v. Diane Cooper, et al., No. 1:25cv1161, 2026 WL 1346605 (M.D.N.C. May 14, 2026), a federal magistrate judge drew a clear line between interpleader as a legitimate procedural tool and interpleader as a cost-shifting mechanism. When an ERISA plan insurer faces competing claims to life insurance proceeds, it has…
Utah Federal Court Grants Partial Discovery in Accidental Death Benefits Dispute, Requires Supplementation of Administrative Record
In Mayor v. Metropolitan Life Insurance Company, No. 1:25-cv-00012, 2026 WL 1339911 (D. Utah May 14, 2026), a Utah federal magistrate judge granted in part and denied in part a claimant’s motion for discovery and sustained in part the claimant’s objection to the completeness of the administrative record in an ERISA accidental death benefits…
Eighth Circuit Affirms AD&D Denial Where Anticoagulant “Contributed To” Fatal Subdural Hematoma
In Beard v. Lincoln Nat’l Life Ins. Co., No. 25-2950, 2026 WL 1279959 (8th Cir. May 11, 2026), the Eighth Circuit affirmed judgment on the administrative record for Lincoln National Life Insurance Company on a claim for accidental death and dismemberment (AD&D) benefits under an ERISA-governed employer plan. Because the plan granted Lincoln National…
N.D. Cal. Enforces North Carolina Choice of Law Provision, Holds California Insurance Code § 10110.6 Does Not Void Discretionary Review
In Farris v. Life Insurance Company of North America, No. 25-cv-04164-RS, 2026 WL 1270071 (N.D. Cal. May 8, 2026), Chief Judge Richard Seeborg granted Defendant Life Insurance Company of North America’s (“LINA”) motion for partial summary judgment, holding that the parties’ North Carolina choice of law provision is enforceable and that California Insurance Code…
Sixth Circuit Affirms Denial of Long-COVID LTD Benefits Under Non-ERISA Federal Reserve Plan, Applying Arbitrary-and-Capricious Review Borrowed from ERISA Case Law
In Martin v. Fed. Rsrv. Bank of Cleveland, et al., No. 25-3518, —F.4th—-2026 WL 1256663 (6th Cir. May 7, 2026), the Sixth Circuit affirmed judgment on the administrative record for the Federal Reserve Bank of Cleveland, Matrix Absence Management, Inc., and the Long Term Disability Income Plan for Employees of the Federal Reserve System.…
When an ERISA Remand Means Starting Over: Court Addresses Claim Deadlines, IME Obligations, and Attorney’s Fees After Procedural Default by Insurer
In Chalk v. Life Insurance Company of North America, No. 3:25-cv-133-RGJ, 2026 WL 1252337 (W.D. Ky. May 7, 2026), District Judge Rebecca Grady Jennings of the United States District Court for the Western District of Kentucky addressed two post-remand disputes in a long-term disability benefits case: whether Plaintiff’s motion to reopen was prematurely filed…