In Watson v. EMC Corp., No. 1:19-CV-02667-RMR-STV, 2025 WL 1333806 (D. Colo. May 7, 2025), on the parties’ joint motion for determination, Colorado District Judge Regina M. Rodriguez found in favor of Plaintiff and against Defendant EMC Corporation, awarding
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Sixth Circuit Clarifies Insurer vs. Fiduciary Capacity in ERISA Dispute
In Bluecross Blueshield of Tennessee, Inc. v. Nicolopoulos, No. 24-5307, 2025 WL 1338242 (6th Cir. May 8, 2025), the Sixth Circuit Court of Appeals addressed an issue central to the intersection of state insurance mandates and federal ERISA regulations.…
Sixth Circuit Affirms Dismissal of ERISA Fiduciary Breach Claim in DENSO 401(k) Case
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…
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…
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…
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…
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…
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…
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…
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:…