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Fifth Circuit Holds That Employee’s Retirement Constitutes a “Qualifying Event” and Triggers Employer’s COBRA Notice Obligation
In Randolph v. E. Baton Rouge Par. Sch. Sys., No. 21-30022, __F.4th__, 2021 WL 5577014 (5th Cir. Nov. 30, 2021), involving a dispute over Consolidated Omnibus Reconciliation Act of 1985…
Second Circuit Holds Union Trustees Were Not Acting as Fiduciaries When They Passed Invalid Amendments to Multiemployer Plans
In Massaro v. Palladino, No. 20-1807, __F.4th__, 2021 WL 5570814 (2d Cir. Nov. 30, 2021), involving an “acrimonious dispute” between the Union and Employer Trustees of two employee benefit plans…
Eighth Circuit: Ordinary Summary Judgment Procedures Apply to Review of ERISA Benefit Claims
Yesterday, in Avenoso v. Reliance Standard Life Ins. Co., No. 21-1772, __F.4th__, 2021 WL 5570816 (8th Cir. Nov. 30, 2021), the Eighth Circuit Court of Appeals weighed in on the…
Third Circuit: Reliance Standard’s Irregular Request for Outside Medical Reports to Deny Disability Claim Is an Abuse of Discretion
Yesterday, the Third Circuit Court of Appeals issued its decision in Noga v. Fulton Financial Corporation Employee Benefit Plan; Reliance Standard Life Insurance Company, No. 19-3855, __F.4th__, 2021 WL 5540848…
Eighth Circuit Holds ERISA Does Not Preempt North Dakota Laws Regulating Pharmacy Benefits Managers
Pharm. Care Mgmt. Ass’n v. Wehbi, No. 18-2926, __F.4th__, 2021 WL 5355916 (8th Cir. Nov. 17, 2021) (Before Smith, Chief Judge, Gruender and Benton, Circuit Judges). On remand from the…
First Circuit: ERISA’s 2002 Regulations Give Disability Claimants Chance to Respond to New Evidence Generated During Administrative Review
Yesterday, in Jette v. United of Omaha Life Ins. Co., No. 20-1713, __F.4th__, 2021 WL 5231971 (1st Cir. Nov. 10, 2021), a case involving a long-term disability claim, the Sixth…
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