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Tenth Circuit Dismisses ERISA Appeal as Non-Final Where District Court Remanded Benefits Determination to Plan Administrator

In Kirsten W. v. California Physicians’ Service, No. 25-4029, 2026 WL 1433128 (10th Cir. May 21, 2026), the Tenth Circuit dismissed an appeal from an ERISA mental-health benefits dispute, concluding…

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Supreme Court Holds ERISA Permits Multiemployer Pension Plans to Use Actuarial Assumptions Adopted After the Measurement Date in Calculating Withdrawal Liability

In M & K Employee Solutions, LLC v. Trustees of the IAM National Pension Fund, No. 23-1209, ___ S.Ct. ___, 2026 WL 1423319 (U.S. May 21, 2026), a unanimous decision…

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When “We Settled” Means Settled: Eastern District of Tennessee Enforces Mediated ERISA Settlement and Awards Unum Its Fees

In Williams v. Unum Life Insurance Company of America, No. 1:25-cv-61, 2026 WL 1412607 (E.D. Tenn. May 19, 2026), United States District Judge Curtis L. Collier granted Unum's motion to…

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Second Circuit Affirms Dismissal of Out-of-Network Provider’s ERISA Claim Where Provider Failed to Establish Beneficiary Status or Valid Assignment and Abandoned Claim on Appeal

In Emsurgcare, Emergency Surgical Assistant v. Hager, No. 25-1975-CV, 2026 WL 1378672 (2d Cir. May 18, 2026), Plaintiffs-Appellants Emsurgcare and Emergency Surgical Assistant (together, “Emsurgcare”) provided emergency surgical services to…

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When Interpleader Serves the Insurer More Than the Beneficiary: Court Denies MetLife Fees in ERISA Life Insurance Dispute

In Metropolitan Life Insurance Company v. Diane Cooper, et al., No. 1:25cv1161, 2026 WL 1346605 (M.D.N.C. May 14, 2026), a federal magistrate judge drew a clear line between interpleader as…

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Utah Federal Court Grants Partial Discovery in Accidental Death Benefits Dispute, Requires Supplementation of Administrative Record

In Mayor v. Metropolitan Life Insurance Company, No. 1:25-cv-00012, 2026 WL 1339911 (D. Utah May 14, 2026), a Utah federal magistrate judge granted in part and denied in part a…

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