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Fifth Circuit Affirms Dismissal of Untimely ERISA § 510 Claim, Rejects Attempt to Recast Claim as Fiduciary Breach
In Mitchell v. H-E-B, L.P., No. 25-50227, 2025 WL 3496980 (5th Cir. Dec. 5, 2025), an unpublished per curiam decision, the Fifth Circuit affirmed summary judgment in favor of H-E-B,…
Eleventh Circuit Upholds Unum’s Termination of Long-Term Disability Benefits Under Arbitrary-and-Capricious Review
In Eggleston v. Unum Life Insurance Company of America, No. 24-13678, 2025 WL 3472834 (11th Cir. Dec. 3, 2025), the Eleventh Circuit affirmed Unum’s decision to terminate a claimant’s long-term…
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.…
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