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Seventh Circuit: Alight Solutions Must Respond to DOL Subpoena in Investigation of Cybersecurity Breaches

In Walsh v. Alight Solutions LLC, No. 21-3290, __F.4th__, 2022 WL 3334450 (7th Cir. Aug. 12, 2022), Defendant-Appellant Alight Solutions LLC, a company that provides administrative services for employers who…

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Eleventh Circuit Denies Pro Se Litigant Rule 60 Relief from Judgment on ERISA Breach of Fiduciary Duty Claim

In Perras v. The Coca-Cola Company of North America, No. 21-13908, 2022 WL 3269970 (11th Cir. Aug. 11, 2022), pro se litigant David Perras appealed the district court’s denial of…

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Eleventh Circuit Blocks Attorney with Parkinson’s Disease from Collecting Benefits Under Two Disability Insurance Policies

Today's decision in Stewart v. Hartford Life and Accident Insurance Company, No. 21-11919, __F.4th__, 2022 WL 3221296 (11th Cir. Aug. 10, 2022) presents a somewhat novel claim made by a…

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Sixth Circuit: In ERISA Suit for Late Benefit Fund Contributions, Presence of a Live Contract Is Not Necessary for District Court’s Jurisdiction

In Operating Engineers’ Loc. 324 Fringe Benefit Funds v. Rieth-Riley Constr. Co., No. 21-1229, 2022 WL 3147929 (6th Cir. Aug. 8, 2022), Plaintiffs-Appellants are a group of employee benefit funds…

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Seventh Circuit: Independent Investment Fiduciary Shields ESOP Fiduciaries from Liability for Investment in Company Stock

Burke v. Boeing Co., No. 20-3389, __F.4th__, 2022 WL 3030835 (7th Cir. Aug. 1, 2022) involves a lawsuit that seeks to hold fiduciaries of the Boeing Voluntary Investment Plan (the…

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Eleventh Circuit: Under De Novo Review of an ERISA Benefit Decision, District Court Cannot Limit Review to the “Administrative Record”

In Harris v. The Lincoln National Life Insurance Company, Lincoln Life Assurance Company of Boston, No. 21-13186, __F.4th__, 2022 WL 3009199 (11th Cir. July 29, 2022), the Eleventh Circuit issued…

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