News and Insights on the latest ERISA litigation trends for employers
In Newsom v. Reliance Standard Life Insurance Company, 2022 U.S. App. LEXIS 4505 (5th Cir. Feb. 18, 2022), the United States Court of Appeals for the Fifth Circuit clarified the difference between an eligibility determination and a disability determination for disability benefits.
James Newsom worked as a software architect for Lereta. He had a…
In a decision illustrating the importance of a deferential standard of review in an ERISA plan document, the Second Circuit affirmed the dismissal of severance claims by a disabled employee, concluding that the complaint pled facts showing that the denial of benefits was reasonable. Soto v. Disney Severance Pay Plan, No. 20-4081 (2d Cir.…
A California district court recently foreclosed a former independent contractor’s claims for benefits from ERISA-governed plans when it found that plaintiff was not a “participant” as defined by ERISA and thus did not have statutory standing to assert his ERISA claims. Alders v. YUM! Brands, Inc., No. 8:21-cv-01191-PSG-DFM (C.D. Cal. Feb. 1, 2022).
After working…
When a district court faces a claim for benefits under ERISA Section 502(a)(1)(B) where it believes that mistakes were made, but the record is not sufficiently developed to award benefits, the court may remand the matter to the plan administrator for further administrative review. Remands such as this have been affirmed by circuit courts for…
In Avenoso v. Reliance Standard Life Insurance Company, No. 21-1772, 2021 U.S. App. LEXIS 35264 (8th Cir. Nov. 30, 2021), the Eighth Circuit clarified its position in a circuit split over the proper judicial procedure for deciding ERISA benefits cases.
The underlying case concerned the defendant’s denial of long-term disability benefits under an ERISA…
In McIntyre v. Reliance Standard Life Insurance Company, 972 F.3d 955 (8th Cir. 2020), the United States Court of Appeals for the Eighth Circuit clarified the standard of review to apply where there has been a denial of benefits challenged under ERISA Section 502(a)(1)(B).
Generally, a court reviews a denial of benefits under a…
The Eastern District of Missouri recently examined whether administrative exhaustion is a prerequisite to an ERISA suit alleging a wrongful denial of employee benefits, where the benefit plan’s language did not include an administrative appeal procedure and the denial letter included only permissive language stating that the claimant “may request a review” of the denial.…
