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Third Circuit Revives Hospitals’ ERISA Underpayment Claims Against Cigna Under MRC-1 and MRC-2 Plans

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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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…

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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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Third Circuit Holds ERISA Preempts Out-of-Network Physician’s Defamation Claim Over Statements in Explanation of Benefits Forms

In Ahn v. Cigna Health and Life Insurance Company, No. 25-1723, --- F.4th ----, 2026 WL 1813215 (3d Cir. June 24, 2026), in a matter of first impression, the Third…

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Ninth Circuit: An ERISA Administrator Cannot Rescue a Benefits Denial with a Plan Provision It Never Cited

In Roggenkamp v. Morgan Stanley Medical Plan, No. 24-7864, 2026 WL 1625357 (9th Cir. June 5, 2026), Plaintiff Roggenkamp sued the Morgan Stanley Medical Plan (“MS Plan”) under ERISA §…

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Tenth Circuit Dismisses ERISA Appeal as Non-Final Where District Court Remanded Benefits Determination to Plan Administrator

In Kirsten W. v. California Physicians’ Service, No. 25-4029, 2026 WL 1433128 (10th Cir. May 21, 2026), the Tenth Circuit dismissed an appeal from an ERISA mental-health benefits dispute, concluding…

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