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Seventh Circuit Holds State Law Claims Seeking Payment and Penalties for Unpaid Medical Bills from Self-Funded Health Plan Are Preempted by ERISA

In Carnes v. HMO Louisiana, Inc., No. 23-2903, __F.4th__, 2024 WL 3873528 (7th Cir. Aug. 20, 2024), Plaintiff-Appellant Carnes appealed the district court’s dismissal of his lawsuit against Defendant HMO…

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Ninth Circuit Revives ERISA Breach of Fiduciary Duty Claims in Class Action Against Northrop Grumman

Baleja v. Northrop Grumman Space and Mission Systems Corp. Salaried Pension Plan, et al., No. 22-56042, 2024 WL 3858720 (9th Cir. Aug. 19, 2024) (Before: Tashima, Graber, and Christen, Circuit…

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In the words of Yoda: Murder Does Not an ERISA Claim Pay

In Standard Ins. Co. v. Guy, No. 21-5562, __F.4th__, 2024 WL 3857926 (6th Cir. Aug. 19, 2024), an interpleader action involving the proceeds of ERISA-governed benefit plans, the Sixth Circuit considered…

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District Court Finds Insurer Committed Numerous Errors and Abused Its Discretion in Terminating Disability Benefits Based on An Improper Application of The Policy’s Mental Health Limitation

In Ehrlich v. Hartford Life and Accident Insurance Co., No. 20-CV-02284-JST, 2024 WL 3745008 (N.D. Cal. Aug. 8, 2024), on Rule 52 cross-motions for judgment, California Northern District Judge Jon…

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District Court Affirms Insurer’s Application of ERISA Disability Policy’s Pre-Existing Condition Exclusion

In Tunkle v. Reliastar Life Insurance Company, No. 2:23-CV-10-SPC-NPM, 2024 WL 3638011 (M.D. Fla. Aug. 2, 2024), on cross-motions for summary judgment, a Florida Middle District Judge granted Defendant Reliastar’s motion,…

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Third Circuit Reverses District Court, Finds Lincoln Financial Group Did Not Abuse Its Discretion When Terminating Long-Term Disability Benefits

In Hawks v. PNC Financial Services Group Inc, et al., No. 23-2636, 2024 WL 3664599 (3d Cir. Aug. 6, 2024), an unpublished opinion, the Third Circuit vacated and remanded the…

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