Eleventh Circuit Holds ERISA’s “Actuarial Equivalent” Requirement Mandates Reasonable Actuarial Assumptions, Joining Sixth Circuit
Eleventh Circuit Holds ERISA’s “Actuarial Equivalent” Requirement Mandates Reasonable Actuarial Assumptions, Joining Sixth Circuit
In Drummond v. Southern Company Services, Inc., No. 24-12773, --- F.4th ----, 2026 WL 1465861 (11th Cir. May 26, 2026), a putative class action brought by two vested participants in…
Eighth Circuit Holds Cumulative Headcount Method Governs “Substantially All” Inquiry Under MPPAA’s Building and Construction Industry Exemption, Affirming GE’s Exemption from Withdrawal Liability
In General Electric Co. v. Boilermaker-Blacksmith National Pension Trust, No. 25-1442, --- F.4th ----, 2026 WL 1466654 (8th Cir. May 26, 2026), the Eighth Circuit Court of Appeals affirmed the…
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…
Supreme Court Holds ERISA Permits Multiemployer Pension Plans to Use Actuarial Assumptions Adopted After the Measurement Date in Calculating Withdrawal Liability
In M & K Employee Solutions, LLC v. Trustees of the IAM National Pension Fund, No. 23-1209, ___ S.Ct. ___, 2026 WL 1423319 (U.S. May 21, 2026), a unanimous decision…
When “We Settled” Means Settled: Eastern District of Tennessee Enforces Mediated ERISA Settlement and Awards Unum Its Fees
In Williams v. Unum Life Insurance Company of America, No. 1:25-cv-61, 2026 WL 1412607 (E.D. Tenn. May 19, 2026), United States District Judge Curtis L. Collier granted Unum's motion to…
Second Circuit Affirms Dismissal of Out-of-Network Provider’s ERISA Claim Where Provider Failed to Establish Beneficiary Status or Valid Assignment and Abandoned Claim on Appeal
In Emsurgcare, Emergency Surgical Assistant v. Hager, No. 25-1975-CV, 2026 WL 1378672 (2d Cir. May 18, 2026), Plaintiffs-Appellants Emsurgcare and Emergency Surgical Assistant (together, “Emsurgcare”) provided emergency surgical services to…
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