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Ninth Circuit Holds ERISA Preempts Provider’s State-Law Misrepresentation Claims Against Insurer
In Healthcare Ally Management of California, LLC v. United Healthcare Services, Inc., No. 24-5178, 2025 WL 3485391 (9th Cir. Dec. 4, 2025), the Ninth Circuit affirmed the dismissal of a…
Sixth Circuit Holds ERISA Completely Preempts State-Law Claims Challenging Insurer’s Reimbursement Practices
In Patterson v. UnitedHealth Group, Inc., No. 25-3175, ---F.4th----, 2025 WL 3458953 (6th Cir. Dec. 2, 2025), the Sixth Circuit affirmed the dismissal of a putative class action alleging that…
Eleventh Circuit Precedent Continues to Shape Limited Discovery in ERISA Cases
In Miller v. American United Life Insurance Co., No. 8:25-CV-1670-KKM-AAS, 2025 WL 3269397 (M.D. Fla. Nov. 24, 2025), the Middle District of Florida granted a claimant’s request for limited discovery…
District of Utah Confirms Only Named Plan Administrator May Face § 1132(c) Penalties
In Mayor v. Metro. Life Ins. Co., itself & as administrator of Union Pac. Corp. Nonagreement Life Ins. Plan 0149653, et al., No. 1:25-CV-00012-DBB-DAO, 2025 WL 3251356 (D. Utah Nov.…
Eleventh Circuit Rules MetLife Properly Terminated Attorney’s Disability Benefits
In Hovan v. Metropolitan Life Insurance Company, No. 24-11167, 2025 WL 3241521 (11th Cir. Nov. 20, 2025), the Eleventh Circuit affirmed summary judgment for MetLife, upholding the insurer’s termination of…
Eleventh Circuit Rejects Reliance Standard’s Broad Interpretation of Preexisting Condition Exclusion
In Johnson v. Reliance Standard Life Insurance Company, No. 23-13443, ---F.4th----, 2025 WL 3251015 (11th Cir. Nov. 21, 2025), a significant decision limiting insurers’ ability to deny early-term disability claims based…
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