District Court Rejects Proposed ERISA Class Challenging NFL Disability Benefits Process for Lack of Commonality and Typicality

In Alford, et al v. The NFL Player Disability, & Survivor Benefit Plan, et al., No. 1:23-CV-00358-JRR, 2026 WL 216349 (D. Md. Jan. 28, 2026), a group of retired National Football League players brought an ERISA class action challenging the administration of disability benefits under the NFL’s disability-related benefit plans. The plaintiffs alleged that the Plan and its Disability Board—acting as plan administrator and fiduciary—systematically tilted the claims process against applicants and unlawfully denied disability benefits through a series of biased and unfair practices. Rather than focusing solely on individual claim denials, the lawsuit was framed as a broader challenge to the structure and operation of the disability claims process.

Claims at Issue

The plaintiffs asserted multiple ERISA causes of action. These included a claim for wrongful denial of benefits under ERISA § 502(a)(1)(B), as well as procedural claims under ERISA § 503 alleging deficient written notice of the reasons for denial and denial of the right to a full and fair review. The plaintiffs also pursued breach of fiduciary duty claims seeking relief on behalf of the Plan itself, contending that the alleged misconduct harmed the integrity of the Plan and warranted systemic remedies.

The Proposed Class and Subclasses

To pursue the case on a representative basis, plaintiffs moved to certify a sweeping class that would include Plan participants who filed disability benefit applications dating back to 1970. They also proposed several subclasses tied to different categories of disability benefits, including Total and Permanent disability claims, claims involving “active” eligibility timing, Line-of-Duty disability claims, and Neurocognitive disability claims. In addition, plaintiffs proposed a broad fiduciary subclass that would cover essentially all disability benefit applicants over the same multi-decade period. The structure reflected plaintiffs’ contention that the challenged conduct was not confined to one benefit type or one timeframe, but instead permeated the entire claims administration process.

Plaintiffs’ Theory of Systemic Bias

The plaintiffs argued that defendants “rigged” the disability claims process through a collection of practices that allegedly disadvantaged applicants and increased the likelihood of denial. They pointed to a wide range of alleged deficiencies, including failing to consider all evidence in claim files, selectively emphasizing unfavorable evidence, and inconsistently treating similarly situated applicants. They also alleged that defendants relied on physicians in a way that undermined impartiality and independence, failed to evaluate impairments in combination, and considered factors that were allegedly prohibited by Plan terms for certain benefit categories. Plaintiffs further contended that decisionmakers relied on undisclosed or “clandestine” interpretations of Plan language and weakened the independence of the appeals process by allowing overlapping involvement of the same advisors at multiple levels of review. Taken together, plaintiffs claimed these practices reflected a coordinated scheme that harmed not only individual applicants but also the Plan itself by wasting assets and eroding the integrity of the benefits process.

Why the Court Denied Class Certification

The District of Maryland denied class certification, focusing on Rule 23(a)’s commonality and typicality requirements. On commonality, the court emphasized that class certification requires more than shared allegations or generalized claims that defendants violated the same legal provisions. Instead, plaintiffs must identify a common contention capable of generating common answers that will drive resolution of the litigation for all class members. In practical terms, the court explained that the key question is not whether plaintiffs can list common “questions,” but whether a classwide proceeding can resolve a central issue in one stroke across the class.

The court found plaintiffs’ theory too broad and too dependent on individualized circumstances to meet that standard. Rather than pointing to a single uniformly applied policy or well-defined practice affecting all claimants in a consistent way, plaintiffs relied on an overarching theory composed of many alleged practices that could manifest differently depending on the claim. The court concluded that determining whether any claimant was harmed—and whether any denial was wrongful—would require a highly individualized inquiry into the claimant’s asserted conditions, the evidence submitted, the relevance of medical records, physician evaluations, and the Board’s handling of each specific claim file. Those differences, the court held, would prevent the litigation from producing common answers applicable to the class as a whole.

Individualized Nature of ERISA Benefit Disputes

The court also noted that the nature of ERISA benefit determinations and related procedural claims further undermined class treatment. Claims for wrongful denial of benefits and violations of ERISA’s procedural safeguards often require careful examination of the administrative record, the communications provided to the claimant, and the decisionmaking process used in that particular case. Where liability turns on individualized claim files and individualized notices, the court reasoned, classwide adjudication becomes difficult—especially when plaintiffs’ theory depends on aggregating multiple alleged practices rather than identifying one discrete policy that drives the outcomes.

Typicality Was Not Met

The court also held that the plaintiffs failed to establish typicality. The proposed class spanned decades, potentially different Plan terms, different medical conditions, and different benefit categories. The court was not persuaded that the named plaintiffs’ experiences were representative of the broad range of absent class members, or that proof of the named plaintiffs’ claims would fairly advance the claims of the class as a whole. Because the alleged practices could affect different claimants in different ways, the court concluded that the named plaintiffs’ claims were not typical of the class claims.

Bottom Line

Because plaintiffs failed to satisfy Rule 23’s commonality and typicality requirements, the court denied the motion for class certification. As a result, the case could not proceed as a class action and instead would move forward, if at all, on an individualized basis rather than through classwide adjudication.