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Northern District of Indiana Refuses ERISA Discovery Into Insurer’s Reviewing Physician Without Prima Facie Evidence of Bias
In Schulmeier v. Lincoln National Life Insurance Company, No. 1:24-CV-284-CCB-ALT, 2026 WL 668269 (N.D. Ind. Mar. 9, 2026), a disability claimant challenged the denial of benefits under ERISA and sought…
Fourth Circuit Holds ERISA § 502(a)(2) Claims in Defined Contribution Plans Are Individualized and Cannot Be Certified as Mandatory Classes
In Trauernicht v. Genworth Fin. Inc., No. 24-1880, ---F.4th----, 2026 WL 667917 (4th Cir. Mar. 10, 2026), the Fourth Circuit reversed a district court’s class certification order in an ERISA…
District of Connecticut Dismisses ERISA § 510 Claim Against Google, Holding Plaintiff Failed to Plausibly Allege Termination Intended to Prevent ERISA Benefits
In Martin v. Google LLC, No. 3:25-CV-587 (SVN), 2026 WL 657265 (D. Conn. Mar. 9, 2026), the U.S. District Court for the District of Connecticut dismissed a former Google sales…
Third Circuit Holds Pension Fund’s Failure to Demand Withdrawal Liability “As Soon as Practicable” Bars Recovery
In RTI Restoration Techs., Inc. v. Int’l Painters & Allied Trades Indus. Pension Fund, No. 24-2874, ---F.4th----, 2026 WL 588429 (3d Cir. Mar. 3, 2026), the Third Circuit affirmed summary…
Fourth Circuit Affirms Termination of Retiree Welfare Benefits Where Plan Reserved Right to Amend or Terminate
In Fitzwater v. Consol Energy, Incorporated, No. 24-2088, 2026 WL 595435 (4th Cir. Mar. 3, 2026), the Fourth Circuit affirmed a district court’s rulings largely in favor of CONSOL Energy…
Second Circuit Holds Plan Fiduciary Breached Duty of Care by Failing to Provide Adequate Notice of Lump-Sum Election During Plan Termination
In Hammell v. Pilot Products, Inc. Defined Benefit Pension Plan, No. 24-3283-CV, 2026 WL 586699 (2d Cir. Mar. 3, 2026), the Second Circuit affirmed a district court judgment finding that…
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