Mealey's ERISA

  • September 18, 2026

    7th Circuit Interpretation Of MPPAA Creates Circuit Split On Withdrawal Liability

    CHICAGO — The Seventh Circuit U.S. Court of Appeals on Sept. 17 affirmed a withdrawal liability ruling that is contrary to decisions by two sister circuits, saying in part that the case involves “complex” statutory provisions “and both sides offer plausible arguments”; the Pension Benefit Guaranty Corp. (PBGC) and the Chamber of Commerce of the United States of America had both filed amicus curiae briefs supporting affirmance.

  • September 18, 2026

    Judge Lets Denials Stand In Case Involving LTD, Disability Insurance Benefits

    CLEVELAND — Granting judgment on the administrative record against a claimant who has epilepsy, an Ohio federal judge concluded that it was not arbitrary and capricious to deny his claims for benefits under a group long-term disability (LTD) policy and an individual disability income policy.

  • September 18, 2026

    Attorney Fee Motions Are Resolved In ‘Contentious’ Deferred Compensation Row

    BURLINGTON, Vt. — Noting that the long-running Employee Retirement Income Security Act dispute concerning deferred compensation “was in the top three percent of contentious cases” she had encountered, a Vermont federal judge awarded less than half of the amounts the parties requested for attorney fees, directing a plaintiff who was a breaching co-fiduciary to pay $189,478.92 for the defendants’ attorney fees and the defendants to pay $320,272.39 for the remaining plaintiffs’ attorney fees and costs.

  • September 17, 2026

    Judge: LTD Claimant With Tinnitus Didn’t Prove He Was Disabled

    OAKLAND, Calif. — After upholding denial of the long-term disability (LTD) the claim of an account executive who argued that conditions including tinnitus and anxiety rendered him disabled, a California federal judge entered judgment against the claimant on Sept. 16; reviewing the denial de novo, the judge said in part that it rested on the claimant’s “failure to demonstrate that the diagnoses resulted in a disability that prevented him from working in his Own Occupation.”

  • September 17, 2026

    LTD Claimant With Parkinson’s Deemed Entitled To Reinstatement

    PORTLAND, Ore. — On de novo review, an Oregon federal magistrate judge ruled that a claimant diagnosed with young-onset Parkinson’s disease (YOPD) is entitled to have her long-term disability (LTD) benefits reinstated under the plan’s “any gainful occupation” definition of disability because the evidence demonstrates that she “suffers from a chronic, degenerative condition that results in cognitive impairments and fatigue which prevent plaintiff from attending work on a reliable and consistent basis, and, when at work, concentrating on her duties.”

  • September 16, 2026

    Judge Imposes $5,000 ERISA Penalty For Late LTD Plan Document Disclosure

    BOSTON — In a memorandum and order citing the prejudice a long-term disability (LTD) claimant suffered and the LTD plan administrator’s “lack of concern for its” statutory obligations under the Employee Retirement Income Security Act, a Massachusetts federal judge decided that the claimant is entitled to a “modest” penalty of $5,000 because the administrator provided plan documents only 230 days after the first of the claimant’s many requests.

  • September 16, 2026

    Judge Sends LTD Claim Back To Insurer Over Mental Health Issue

    SALT LAKE CITY — On de novo review, a Utah federal judge ruled that a long-term disability (LTD) insurer must reconsider whether a claimant qualifies for benefits under an any-occupation definition of disability because it relied on an employability analysis report that was based on a medical case manager review that “missed all evidence of mental health treatment and care in the record.”

  • September 15, 2026

    Claimant Takes Dispute Over ‘Any-Occupation’ LTD Benefits To 11th Circuit

    TAMPA, Fla. — A claimant who unsuccessfully challenged termination of her long-term disability (LTD) benefits under an any-occupation definition of disability filed a Sept. 14 notice in Florida federal court that she is taking the case to the 11th Circuit U.S. Court of Appeals.

  • September 09, 2026

    Judge Sends LTD Claim Back To Insurer Over Cognitive Demands Issue

    DENVER — Reversing the denial of a claim for long-term disability (LTD) benefits, a Colorado federal judge said that “none of the evidence” the insurer relied on compared the claimant’s “cognitive functioning to the actual requirements of his position as a software engineer, or his ability to perform those functions on a continuous work schedule” and therefore the decision “is not founded on substantial evidence” and must go back to the insurer “for further consideration.”

  • September 09, 2026

    11th Circuit Affirms Judgment For LTD Insurer In Dispute Over Tax Returns

    ATLANTA — Affirming summary judgment for an insurer that terminated a claimant’s long-term disability (LTD) benefits, the 11th Circuit U.S. Court of Appeals said in an unpublished opinion that the insurer needed the documents to evaluate whether the claimant “satisfied the Test of Disability, so his refusal to provide them justified termination under the Plan.”

  • September 09, 2026

    Citing Bakery Drivers, Plans Ask Court To Get Them Off Agency’s SFA Waitlist

    WASHINGTON, D.C. — Under a stipulation a District of Columbia federal judge granted in a text-only docket entry, the Pension Benefit Guaranty Corp. (PBGC) has until Sept. 16 to respond to a preliminary injunction request from 22 terminated multiemployer pension plans that allege that the agency is using an improper “waitlist scheme” to prevent them and their “25,000 participants and beneficiaries” from claiming special financial assistance (SFA) funding “that is likely to total in the hundreds of millions of dollars.”

  • September 08, 2026

    DOL Files Amicus Brief Before Full 5th Circuit Hears Surcharge Dispute

    NEW ORLEANS — Oral argument before the en banc Fifth Circuit U.S. Court of Appeals is scheduled for Sept. 24 in a case that group health plans and related entities filed against a third-party administrator (TPA), and the U.S. Department of Labor (DOL) has filed an amicus curiae brief urging the appellate court to “reaffirm that surcharge is an equitable remedy in suits brought under” the Employee Retirement Income Security Act.

  • September 04, 2026

    Colorado Federal Judge Adds ‘No Standing’ Ruling In Wave Of PRT Cases

    DENVER — Saying there is a lack of “controlling authority to guide the Court’s analysis,” a Colorado federal judge found that retirees lacked standing to bring a putative class case that is part of a wave of pension risk transfer (PRT) challenges; he therefore granted dismissal without prejudice of all the claims in the Employee Retirement Income Security Act case.

  • September 04, 2026

    1st Argument In Appeals From Wave Of Tobacco Surcharge Cases Is Set

    The First Circuit U.S. Court of Appeals has scheduled oral argument for Sept. 16 in the most advanced appeal arising from a wave of putative class Employee Retirement Income Security Act challenges to tobacco surcharges, and at least five similar appeals are under way.

  • September 03, 2026

    Judge Grants Preliminary Injunction As To Part Of Illinois PBM Law

    SPRINGFIELD, Ill. — Granting a trade association’s motion for a preliminary injunction, an Illinois federal judge enjoined the Illinois Department of Insurance from enforcing a state law’s reporting requirements against the association’s members that are pharmacy benefit managers (PBMs) serving health plans sponsored by employers and unions that are subject to the Employee Retirement Income Security Act.

  • September 02, 2026

    Termination Of ‘Any-Occupation’ LTD Benefits Survives 8th Circuit Review

    ST. LOUIS — Saying in part that there was no clear error in the lower court’s refusal to credit a treating physician’s attempt to “walk back” his opinions that the claimant was capable of sedentary work, the Eighth Circuit U.S. Court of Appeals affirmed termination of long-term disability (LTD) benefits under an “any gainful occupation” definition of disability.

  • September 02, 2026

    9th Circuit Issues ‘Substantial Compliance’ Ruling In ERISA Pension Case

    SAN FRANCISCO — Applying the California doctrine of substantial compliance in an Employee Retirement Income Security Act case focused on an online effort to make a pension benefit election and designate a beneficiary, the Ninth Circuit U.S. Court of Appeals reversed dismissal of one benefits claim and remanded for further proceedings; however, in a separate unpublished memorandum disposition, the appellate panel affirmed dismissal of two other claims.

  • September 01, 2026

    9th Circuit Revives ERISA Challenge To Management Of Multiemployer Plan

    PASADENA, Calif. — Reviving a class action focused on the management of a multiemployer plan that used a single investment pool, the Ninth Circuit U.S. Court of Appeals said in an unpublished memorandum that the trial court “did not have the benefit of” a decision in which the appellate court subsequently addressed how to assess claims concerning the duty of prudence under the Employee Retirement Income Security Act.

  • September 01, 2026

    Government To High Court: Deny Certiorari Petition Concerning Top-Hat Plans

    WASHINGTON, D.C. — Urging the U.S. Supreme Court to deny a certiorari petition filed by participants in “top hat” deferred compensation and retirement plans, the U.S. government says in an Aug. 31 amicus curiae brief that the Sixth Circuit U.S. Court of Appeals “erred in its analysis of surcharge” but “this case’s idiosyncratic factual context makes it an unsuitable vehicle for clarifying the propriety of surcharge relief” under the Employee Retirement Income Security Act; simultaneously, the U.S. Department of Labor (DOL) asked the Fifth Circuit for permission to file a late amicus brief in a separate ERISA case arguing that “surcharge is a form of ‘appropriate equitable relief’ that may be awarded for claims brought against fiduciaries for breaches of fiduciary duties.”

  • August 31, 2026

    3rd Circuit Won’t Rehear Hospital Underpayment Case It Partly Revived

    PHILADELPHIA — Denying health insurers’ petition for rehearing but granting what it construed as hospitals’ request to modify a footnote, the Third Circuit U.S. Court of Appeals issued an amended nonprecedential opinion partly reviving an Employee Retirement Income Security Act suit in which the hospitals allege that they were underpaid by at least $100 million for claims for out-of-network reimbursement.

  • August 31, 2026

    Affirming LTD Benefits Denial, 5th Circuit Skirts Choice-Of-Law Issues

    NEW ORLEANS — Skirting “thorny choice-of-law issues” but expressing doubt that a plan governed by the Employee Retirement Income Security Act “can tell its insured that no state law applies to him,” the Fifth Circuit U.S. Court of Appeals issued an unpublished opinion affirming denial of long-term disability (LTD) benefits on the grounds that the claimant “was not totally disabled” even under de novo review.

  • August 28, 2026

    11th Circuit: Insurer’s Termination Of LTD Benefits Was Sufficiently Supported

    ATLANTA — Issuing an unpublished Aug. 27 opinion affirming a ruling against a pro se claimant whose long-term disability (LTD) benefits were terminated under an any-occupation definition of disability, the 11th Circuit U.S. Court of Appeals said it was reasonable for the insurer “to rely on the findings of four medical professionals, in conjunction with the independent medical examination and the two vocational assessments, to find that [she] no longer met the definition of disabled under the policy because she could perform sedentary jobs in her area.”

  • August 28, 2026

    7th Circuit Affirms Decision Against Fund That Sought ERISA Preemption Ruling

    CHICAGO — Saying the appeal required “a straightforward application of one Supreme Court precedent, and a careful analysis of another,” the Seventh Circuit U.S. Court of Appeals affirmed dismissal of a suit that sought a declaration that the Employee Retirement Income Security Act preempted two parts of a state regulation implementing the Arkansas Pharmacy Benefits Manager Licensure Act.

  • August 28, 2026

    N.Y. Federal Judge OKs Class Settlement, But Not Service Awards, In ESOP Case

    NEW YORK — Granting final approval of a settlement that a class of employee stock ownership plan (ESOP) participants said “will deliver more than $22.5 million in total economic value through a combination of cash, loan reductions, and liquidity provisions,” a New York federal judge awarded $6.2 million for attorney fees and $727,406.93 for litigation expenses and $35,000 for settlement administration expenses as requested — but denied a request for two $10,000 service awards for the named plaintiffs.

  • August 28, 2026

    4th Circuit To Hear 1st Argument In Appeals From Wave Of PRT Cases

    RICHMOND, Va. — The most advanced of the appeals springing from a wave of pension risk transfer (PRT) cases filed under the Employee Retirement Income Security Act is in the Fourth Circuit, where oral argument with the U.S. Department of Labor (DOL) participating as amicus curiae is scheduled for Sept. 16.