Sixth Circuit Holds ERISA Expressly Preempts Out-of-Network Providers’ Negligent-Misrepresentation and Promissory-Estoppel Claims Based on a Plan Administrator’s Oral Reimbursement Assurances
Sixth Circuit Holds ERISA Expressly Preempts Out-of-Network Providers’ Negligent-Misrepresentation and Promissory-Estoppel Claims Based on a Plan Administrator’s Oral Reimbursement Assurances
In Laurel Hill Mgmt. Servs., Inc. v. La-Z-Boy Inc., No. 25-1727, --- F.4th ----, 2026 WL 2427143 (6th Cir. Aug. 19, 2026), several out-of-network medical providers treated a patient covered…
Seventh Circuit Affirms Class Certification but Reverses Summary Judgment Against Alcoa in Pre-1993 Retiree Healthcare Vesting Dispute
In Kaiser v. ALCOA USA Corp., No. 25-1627, --- F.4th ----, 2026 WL 2364300 (7th Cir. Aug. 14, 2026), Plaintiff, on behalf of herself and a class of former Alcoa…
Ninth Circuit Holds ERISA Does Not Preempt Out-of-Network Provider’s Negligent Misrepresentation Claim Arising from Aetna’s Verification-Call Statements, But Affirms Preemption of Promissory Estoppel Claim
In Healthcare Ally Management of California, LLC v. WSP USA, Inc., No. 24-3479, --- F.4th ----, 2026 WL 2319896 (9th Cir. Aug. 11, 2026), an out-of-network surgery center, La Peer,…
Third Circuit Revives Hospitals’ ERISA Underpayment Claims Against Cigna Under MRC-1 and MRC-2 Plans
In Hudson Hospital OPCO, LLC v. Cigna Health & Life Insurance Co., No. 24-2830, 2026 WL 2057076 (3d Cir. July 16, 2026), three New Jersey hospitals appealed the dismissal of…
Third Circuit Revives ERISA Recovery and Fiduciary-Breach Claims Tied to Cigna’s MRC-1 Out-of-Network Reimbursements
In Advanced Gynecology & Laparoscopy of North Jersey P.C. v. Cigna Health & Life Insurance Co., No. 24-2212, 2026 WL 2030368 (3d Cir. July 13, 2026), nearly two dozen New…
Eighth Circuit Holds ERISA Preempts Arkansas’s Geographic Pharmacy Network Adequacy Requirements, Affirming Dismissal of Plan Participant’s Unjust Enrichment Class Action
In Flowers v. Caremark PCS Health, LLC, No. 25-3068, --- F.4th ----, 2026 WL 1859929 (8th Cir. June 29, 2026), the Eighth Circuit held that ERISA preempts Arkansas's geographic pharmacy…
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