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First Circuit Holds Health Plan’s Third-Party Administrator Is Not an ERISA Fiduciary with Respect to Overpayments to Medical Providers

In Massachusetts Laborers’ Health & Welfare Fund v. Blue Cross Blue Shield of Massachusetts, No. 22-1317, 2023 WL 3069637 (1st Cir. Apr. 25, 2023), a dispute between the Massachusetts Laborers’…

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District Court Finds Insurer Properly Applied ERISA Plan Language Prorating Plaintiff’s Lump Sum Pension Benefits as An Offset to Long-Term Disability Benefits

In Walker v. Reliance Standard Life Insurance Company, No. 2:22-CV-109, 2023 WL 3066708 (E.D. Tenn. Apr. 24, 2023) Tennessee Eastern District Judge Travis R. McDonough granted judgment in favor of…

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Sixth Circuit Reverses Employer Win on Benefit Funds’ Claim for Unpaid Benefit Contributions

In Trustees of Sheet Metal Workers Loc. 7 Zone 1 Pension Fund v. Pro Servs., Inc., No. 22-1566, 2023 WL 3029735 (6th Cir. Apr. 21, 2023), a suit brought by…

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District Court Finds ERISA Plan Does Not Require Exhaustion of Administrative Remedies As Prerequisite to Filing Suit

In Jackson v. The Guardian Life Insurance Company of America, et al., No. 22-CV-03142-JSC, 2023 WL 2960290 (N.D. Cal. Apr. 13, 2023), Northern District of California District Judge Jacqueline Scott…

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District Court Upholds Unum’s Termination of Disability Benefits After 24 Months Because Plaintiff Did Not Remain Disabled Strictly Due to a Physical Condition

In Abi-Aad v. Unum Group, Unum Life Insurance Company of America, No. 21-CV-11862-AK, 2023 WL 2838357 (D. Mass. Apr. 7, 2023), Massachusetts District Judge Angel Kelley granted judgment to Unum…

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Third Circuit Holds New Jersey Transit Corporation Cannot be Sued for Disability Pension Benefits under ERISA Due to Governmental Plan Exemption

In Pue v. New Jersey Transit Corporation, No. 22-2616, 2023 WL 2930298 (3d Cir. Apr. 13, 2023), the pro se Plaintiff-Appellant Anthony Pue filed a lawsuit against New Jersey Transit…

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