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).