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Seventh Circuit Affirms Denial of Survivor Benefits Where Power of Attorney Lacked Express Authority to Waive Spousal Annuity Rights Under ERISA

In Havlik v. University of Chicago, No. 25-2821, --- F.4th ----, 2026 WL 2084784 (7th Cir. July 20, 2026), a suit for ERISA benefits, the Seventh Circuit affirmed summary judgment…

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ERISA “Any Occupation” Standard Defeats MS Claimant: N.D. Illinois Court Upholds Unum’s Long-Term Disability Denial on De Novo Review

In Scorzo v. Unum Life Insurance Company of America, No. 23-cv-3836, 2026 WL 2070002 (N.D. Ill. July 17, 2026), United States District Judge Jeffrey I. Cummings granted judgment to Unum…

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Seventh Circuit Affirms That ESOP Fiduciaries Did Not Breach Their Duties or Engage in a Prohibited Transaction in Approving the Sale of an ESOP-Owned Company

In Rush v. GreatBanc Trust Co., No. 25-1736, --- F.4th ----, 2026 WL 2071139 (7th Cir. July 17, 2026), the Seventh Circuit affirmed a defense judgment entered after a three-week…

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When “Sedentary” Isn’t the Whole Job: California Court Restores 20 Years of ERISA Disability Benefits Reliance Standard Cut Off

In Cyr v. Reliance Standard Life Insurance Company, No. 2:23-cv-06286-DSF-RAO, 2026 WL 2056667 (C.D. Cal. July 15, 2026), United States District Judge Dale S. Fischer, following a bench trial on…

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Third Circuit Revives Hospitals’ ERISA Underpayment Claims Against Cigna Under MRC-1 and MRC-2 Plans

In Hudson Hospital OPCO, LLC v. Cigna Health & Life Insurance Co., No. 24-2830, 2026 WL 2057076 (3d Cir. July 16, 2026), three New Jersey hospitals appealed the dismissal of…

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When Can an ERISA Claimant Get Discovery Beyond the Administrative Record? A New York Court Draws the Line

In De Mello v. First Unum Life Insurance Company, No. 25-cv-7933 (LJL), 2026 WL 2032059 (S.D.N.Y. July 14, 2026), United States District Judge Lewis J. Liman denied an ERISA long-term…

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