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Western District of Michigan Holds Insured Disabled from Own Occupation Due to Intractable Headaches but Not from Any Gainful Occupation

Western District of Michigan Holds Insured Disabled from Own Occupation Due to Intractable Headaches but Not from Any Gainful Occupation

In Tobin v. Unum Life Insurance Company of America, No. 1:24-CV-1012, 2026 WL 508810 (W.D. Mich. Feb. 13, 2026), the Western District of Michigan, applying de novo review, held that…

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Pre-Existing Condition Exclusion Bars LTD Claim Based on Prior Treatment for Low Back Pain

In Hudson v. Principal Life Insurance Co., No. 24-1308 (JRT/ECW), 2026 WL 496683 (D. Minn. Feb. 23, 2026), the District of Minnesota held that a long-term disability claim was barred…

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District of Vermont Upholds Denial of Disability Benefits Where Employee Alleged Long COVID But Objective Evidence Did Not Support Disability Before Termination

In Weiss v. Lincoln National Life Insurance Company & Verista, Inc., No. 2:24-CV-00591-CR, 2026 WL 483280 (D. Vt. Feb. 20, 2026), the U.S. District Court for the District of Vermont…

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Second Circuit Rejects Pension Fund’s Double-Counting Theory and Eliminates $1.8 Million in Withdrawal Liability

In Mar-Can Transportation Co., Inc. v. Loc. 854 Pension Fund, No. 24-1431, ---F.4th----, 2026 WL 452565 (2d Cir. Feb. 18, 2026), the Second Circuit resolved a significant statutory interpretation dispute…

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Western District of Washington Dismisses ERISA Claims Challenging Aviation Exclusion in AD&D Policy

In Aloff v. The Prudential Insurance Company of America et al., No. 3:25-CV-05834-DGE, 2026 WL 445565 (W.D. Wash. Feb. 17, 2026), the U.S. District Court for the Western District of…

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District Court Enforces Massachusetts Choice-of-Law Clause in ERISA Case, Rejects California Ban on Discretionary Clauses

In Hildebrandt v. Unum Life Insurance Company of America, No. 8:23-CV-02297-ODW (JDEX), 2026 WL 413748 (C.D. Cal. Feb. 13, 2026), the Central District of California enforced a Massachusetts choice-of-law provision…

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