En Banc Eleventh Circuit Holds That ERISA Does Not Require Administrative Exhaustion of Statutory Claims, Including Breach of Fiduciary Duty Claims, and Overrules Four Decades of Circuit Precedent
En Banc Eleventh Circuit Holds That ERISA Does Not Require Administrative Exhaustion of Statutory Claims, Including Breach of Fiduciary Duty Claims, and Overrules Four Decades of Circuit Precedent
In Bolton v. Inland Fresh Seafood Corp. of America, Inc., No. 24-10084, --- F.4th ----, 2026 WL 3056461 (11th Cir. Oct. 13, 2026), sitting en banc, the Eleventh Circuit overruled…
When Dependent Life Coverage Ends at Divorce: Court Dismisses ERISA Benefits and Fiduciary-Breach Claims Despite an Employer’s Admitted Mistake
In Wright v. Hartford Life and Accident Insurance Company, No. 3:25-CV-297-CHB, 2026 WL 2925146 (W.D. Ky. Sept. 29, 2026), a Kentucky federal court granted motions to dismiss both the ERISA…
Fifth Circuit Affirms Summary Judgment Holding Company Owner a Functional ERISA Fiduciary Personally Liable for Diverted Employee Contributions and Unpaid Health Claims
In Sonderling v. Sills, No. 26-30272, 2026 WL 3001434 (5th Cir. Oct. 6, 2026) (Before: Davis, Stewart, and Duncan, Circuit Judges), the Acting Secretary of Labor sued Kelly Sills, president…
ERISA Surcharge Against an Employer-Fiduciary: New Mexico District Court Lets a Lapsed Group Life Insurance Claim Proceed
In Vigil v. Taos Ski Valley, Inc., No. 1:25-cv-01323-KWR-JFR, 2026 WL 2883448 (D.N.M. Sept. 25, 2026), United States District Judge Kea W. Riggs denied an employer's motion for judgment on…
When Divorce Ends Employer Health Coverage: Court Dismisses Former Spouse’s ERISA Claims as Untimely and Preempted
In Ioannidis v. Benefit Program for Mass General Brigham and Membership Organization Plan (501), No. 25-12197-FDS, 2026 WL 2874084 (D. Mass. Sept. 24, 2026), District Judge Saylor granted the defendants’…
ERISA Fiduciary Status and Medical Advisory Physicians: New Jersey Court Dismisses Breach Claims Against NFL Disability Plan Doctors
In Glaud v. NFL Player Disability and Survivor Benefit Plan, No. 25-cv-15373-ESK-EAH, 2026 WL 2664386 (D.N.J. Sept. 10, 2026), United States District Judge Edward S. Kiel dismissed with prejudice two…
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