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Use It or Lose It: Court Won’t Strike Guardian’s Declaration in an ERISA Preemption Dispute After the Claimant Sat Out Discovery

Use It or Lose It: Court Won’t Strike Guardian’s Declaration in an ERISA Preemption Dispute After the Claimant Sat Out Discovery

In Hannon v. Guardian Life Insurance Company of America, No. 25-13431-LTS, 2026 WL 3093200 (D. Mass. Oct. 16, 2026), a Massachusetts federal court confronted a recurring question in ERISA litigation:…

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Can an ERISA Claimant Get Discovery Beyond the Administrative Record? Minnesota Court Permits Extra-Record Discovery on a Separately Pleaded Breach-of-Fiduciary-Duty Claim Against Unum

In Gibson v. Unum Life Insurance Company of America, No. 25-2711 (JWB/JFD), 2026 WL 2983259 (D. Minn. Oct. 5, 2026), a Minnesota federal court allowed an ERISA long-term disability claimant…

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Does a Late ERISA Appeal Decision Cost the Insurer Deference? Court Reviews Hartford’s Long-Term Disability Denial De Novo and Vacates It

In Farley v. Hartford Life and Accident Insurance Company, No. 4:24-cv-00894-SEP, 2026 WL 2971836 (E.D. Mo. Sept. 30, 2026), the United States District Court for the Eastern District of Missouri…

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S.D. Cal.: ERISA Governs a “Voluntary” Supplemental Disability Policy, and the Benefits Claim Falls Short

In Whitlock v. Provident Life and Accident Insurance Company, No. 25-cv-0964-AGS-VET (S.D. Cal. Sept. 30, 2026), the Southern District of California confronted a recurring question for anyone with an employer-offered…

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No Deference, No Clawback: ERISA Court Rejects Unum’s Discretionary Review and Its Bid to Recover Alleged Overpayments

In Krambeck v. Unum Life Insurance Company of America, No. 8:24-cv-2102-TPB-NHA, 2026 WL 2935928 (M.D. Fla. Sept. 30, 2026), Judge Tom Barber of the United States District Court for the…

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When an ERISA Plan Doesn’t State the Deadline: Court Refuses to Enforce a One-Year Limitations Period and Penalizes an Employer for Failing to Produce the Plan

In Thomas v. Amazon.com Services, Inc., No. 4:21-CV-02997, 2026 WL 2934940 (S.D. Tex. Sept. 29, 2026), a Texas federal court issued findings of fact and conclusions of law after a…

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