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Eleventh Circuit: Under De Novo Review of an ERISA Benefit Decision, District Court Cannot Limit Review to the “Administrative Record”
In Harris v. The Lincoln National Life Insurance Company, Lincoln Life Assurance Company of Boston, No. 21-13186, __F.4th__, 2022 WL 3009199 (11th Cir. July 29, 2022), the Eleventh Circuit issued…
Fourth Circuit: Company Manifested Intent to be Bound by CBA and Is Subject to Exit Contributions under ERISA
In Bd. of Trustees, Sheet Metal Workers’ Nat’l Pension Fund v. Four-C-Aire, Inc., No. 20-2181, __F.th__, 2022 WL 2963188 (4th Cir. July 27, 2022), the Board of Trustees for the…
Ninth Circuit Holds ERISA Health Plan’s Self-Help Provision Is Enforceable
The Ninth Circuit Court of Appeals recently decided Mull v. Motion Picture Indus. Health Plan, No. 20-56315, __F.4th__, 2022 WL 2912475 (9th Cir. July 25, 2022). This matter involves a…
First Circuit Construes Life Insurance Policy Ambiguities Against Reliance Standard and Affirms Over $1.1 Million Award to Widow
In Ministeri v. Reliance Standard Life Ins. Co., No. 21-1651, __F.4th__, 2022 WL 2914068 (1st Cir. July 25, 2022), following its sister circuits, the First Circuit Court of Appeals just…
Ninth Circuit Holds Equitable Tolling and Equitable Estoppel Do Not Apply to Statute of Limitations in ERISA Case
In Serafin v. William C. Earhart Company Inc., et al., No. 20-35147, 2022 WL 2828223 (9th Cir. July 20, 2022) (Before: Schroeder, R. Nelson, and Vandyke, Circuit Judges), a short…
Ninth Circuit: ERISA Plan Must Arbitrate Dispute Against Its Claims Administrator
In Board of Trustees of The IBEW Local No. 640 And Arizona Chapter NECA Health and Welfare Trust Fund v. Cigna Health and Life Insurance Company, No. 21-16424, 2022 WL…
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