Can ERISA Claimants Sue Anonymously? A Court’s Measured Answer in a Mental Health Treatment Denial Case
Can ERISA Claimants Sue Anonymously? A Court’s Measured Answer in a Mental Health Treatment Denial Case
In J.W. v. Quantum Health, Inc., 2026 WL 2654147 (S.D. Ohio Sept. 9, 2026), United States Magistrate Judge Kimberly A. Jolson confronted a question that ERISA claimants pursuing mental health…
Third Circuit Vacates Dismissal of Hospitals’ ERISA Underpayment Claims Under MRC-1 and MRC-2 Plans, Affirms Dismissal of R&C and Fiduciary-Duty Claims
In Hudson Hospital OPCO, LLC v. Cigna Health and Life Insurance Company, No. 24-2830, 2026 WL 2511311 (3d Cir. Aug. 26, 2026), three New Jersey hospitals—Christ Hospital, Bayonne Medical Center,…
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…
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