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Second Circuit Holds Plan Fiduciary Breached Duty of Care by Failing to Provide Adequate Notice of Lump-Sum Election During Plan Termination

Second Circuit Holds Plan Fiduciary Breached Duty of Care by Failing to Provide Adequate Notice of Lump-Sum Election During Plan Termination

In Hammell v. Pilot Products, Inc. Defined Benefit Pension Plan, No. 24-3283-CV, 2026 WL 586699 (2d Cir. Mar. 3, 2026), the Second Circuit affirmed a district court judgment finding that…

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Fourth Circuit Finds ERISA Administrator Forfeits Deference by Missing Appeal Deadline

In Cogdell v. Reliance Standard Life Ins. Co., No. 24-1940, ---F.4th----, 2026 WL 588427 (4th Cir. Mar. 3, 2026), a published decision, the Fourth Circuit held that a plan administrator’s…

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Fifth Circuit Affirms Abuse-of-Discretion Review and Denial of Change-of-Control Severance Benefits

In Miller v. Anadarko Petroleum Corporation Change of Control Severance Plan, No. 25-20113, 2026 WL 542628 (5th Cir. Feb. 26, 2026), the Fifth Circuit affirmed summary judgment in favor of…

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District of Arizona Holds Reliance Standard Abused Its Discretion by Demanding Objective Proof of Chronic Fatigue and Failing to Evaluate the Record as a Whole

In Guy v. Reliance Standard Life Insurance Co., No. 2:24-CV-00293-JCG, 2026 WL 539534 (D. Ariz. Feb. 20, 2026), the U.S. District Court for the District of Arizona reversed Reliance’s denial…

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Central District of California Affirms Termination of LTD Benefits After Expiration of 24-Month Mental Disorder Limitation

In Talley v. Provident Life and Accident Insurance Company, No. 8:24-CV-01860-FWS-DFM, 2026 WL 523704 (C.D. Cal. Feb. 25, 2026), the Central District of California, applying de novo review, upheld an…

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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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