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When a Life Insurance Policy Falls Outside ERISA: Texas District Court Applies the Sole-Owner Exception and Resolves Beneficiary Dispute Under State Law
In Principal Life Insurance Co. v. Jones, No. 3:25-cv-00221, 2026 WL 1480286 (S.D. Tex. May 27, 2026), Magistrate Judge Andrew M. Edison recommended that summary judgment be granted to the…
When an ERISA Judgment Becomes Uncollectable: Fourth Circuit Holds That Voluntary Dismissal of Alleged Alter Ego Forecloses Later Suit to Pierce Corporate Veil
In Messer v. Garrison Investment Group, LP, --- F.4th ----, 2026 WL 1465139 (4th Cir. May 26, 2026), the Fourth Circuit affirmed the dismissal of a class action in which…
Eleventh Circuit Holds ERISA’s “Actuarial Equivalent” Requirement Mandates Reasonable Actuarial Assumptions, Joining Sixth Circuit
In Drummond v. Southern Company Services, Inc., No. 24-12773, --- F.4th ----, 2026 WL 1465861 (11th Cir. May 26, 2026), a putative class action brought by two vested participants in…
Eighth Circuit Holds Cumulative Headcount Method Governs “Substantially All” Inquiry Under MPPAA’s Building and Construction Industry Exemption, Affirming GE’s Exemption from Withdrawal Liability
In General Electric Co. v. Boilermaker-Blacksmith National Pension Trust, No. 25-1442, --- F.4th ----, 2026 WL 1466654 (8th Cir. May 26, 2026), the Eighth Circuit Court of Appeals affirmed the…
Tenth Circuit Dismisses ERISA Appeal as Non-Final Where District Court Remanded Benefits Determination to Plan Administrator
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…
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…
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