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Fifth Circuit Affirms Dismissal of Untimely ERISA § 510 Claim, Rejects Attempt to Recast Claim as Fiduciary Breach

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In Mitchell v. H-E-B, L.P., No. 25-50227, 2025 WL 3496980 (5th Cir. Dec. 5, 2025), an unpublished per curiam decision, the Fifth Circuit affirmed summary judgment in favor of H-E-B,…

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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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Second Circuit Affirms Dismissal of Fiduciary-Breach Claims Over High-Risk Investment Strategy

In Carlisle v. The Board of Trustees of The American Federation of The New York State Teamsters Conference Pension and Retirement Fund, et al., No. 25-511-CV, 2025 WL 3251154 (2d…

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Court Allows Plaintiff to Pursue Both ERISA Benefit Denial and Fiduciary Duty Claims Against MetLife

In Salhoub v. Metropolitan Life Insurance Company, No. CV 25-2196-KHV, 2025 WL 2938995 (D. Kan. Oct. 16, 2025), the United States District Court for the District of Kansas denied MetLife’s…

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Eleventh Circuit Reaffirms Strict ERISA Exhaustion Requirement for Fiduciary-Breach Claims

In Bolton v. Inland Fresh Seafood Corp. of Am., Inc., No. 24-10084, ---F.4th----, 2025 WL 2924493 (11th Cir. Oct. 15, 2025), the Eleventh Circuit affirmed dismissal of a class action…

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Third Circuit Rejects ERISA “Equitable Relief” Claim Duplicative of Benefit Claim and Affirms Denial of Pension Appeal

In Carr v. Jefferson Defined Benefit Plan, et al., No. 24-2574, 2025 WL 2888014 (3d Cir. Oct. 10, 2025), a non-precedential opinion, the Third Circuit affirmed summary judgment for the…

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