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Eleventh Circuit Reaffirms Strict ERISA Exhaustion Requirement for Fiduciary-Breach Claims
In Bolton v. Inland Fresh Seafood Corp. of Am., Inc., No. 24-10084, ---F.4th----, 2025 WL 2924493 (11th Cir. Oct. 15, 2025), the Eleventh Circuit affirmed dismissal of a class action…
District Court Upholds Slayer Statute to Deny ERISA Life Insurance Proceeds to Convicted Killer
In Stacy v. The Hartford, No. 4:25-CV-6, 2025 WL 2860049 (E.D. Tenn. Oct. 9, 2025), Judge Travis R. McDonough of the U.S. District Court for the Eastern District of Tennessee…
Court Partially Grants Discovery in ERISA Disability Case Against Hartford Life
In Gannon, MD v. Hartford Life and Accident Ins. Co., No. 3:24-CV-01955 (VAB), 2025 WL 2886648 (D. Conn. Oct. 3, 2025), the District of Connecticut addressed how far claimants can…
Third Circuit Rejects ERISA “Equitable Relief” Claim Duplicative of Benefit Claim and Affirms Denial of Pension Appeal
In Carr v. Jefferson Defined Benefit Plan, et al., No. 24-2574, 2025 WL 2888014 (3d Cir. Oct. 10, 2025), a non-precedential opinion, the Third Circuit affirmed summary judgment for the…
Seventh Circuit Holds Pension Fund Need Not Adjust Payment Schedule for Asset Sales Under ERISA’s “Safe Harbor” Provision
In Supervalu, Inc. v. United Food and Commercial Workers Unions and Employers Midwest Pension Fund, No. 24-2486, ---F.4th----, 2025 WL 2860665 (7th Cir. Oct. 9, 2025), the Seventh Circuit held…
Court Upholds Employer’s Denial of Long-Term Disability Benefits and Rejects Fiduciary Exception to Attorney-Client Privilege
In Pasha v. Kohler Co., No. 24-CV-0836-BHL, 2025 WL 2840242 (E.D. Wis. Oct. 7, 2025), the U.S. District Court for the Eastern District of Wisconsin upheld Kohler Co.’s decision to…
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