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Supreme Court Lowers Bar to Pleading Prohibited Transactions, Despite “Serious Concerns” of Meritless Litigation

In a unanimous decision reversing dismissal of prohibited transaction claims based on fees paid to defined contribution plan recordkeepers, the Supreme Court held that ERISA’s prohibited transaction exemptions are affirmative...more

Executive Order on Health Care Access for Gender-Affirming Treatments for Minors

Following through on a campaign theme focused on transgender issues and access to gender-affirming health care, on Friday, January 28, President Trump signed an Executive Order, titled “Protecting Children from Chemical and...more

Second Circuit Holds that Plan Arbitration Provisions that Force Plaintiff to Surrender Statutory Right To Plan-Wide Relief Are...

The Second Circuit recently ruled that an ERISA plan’s arbitration provision was not enforceable because the provision barred plan-wide relief. Cedeno v. Sasson, 2024 WL 1895053 (2d Cir. May 1, 2024). The Court decision...more

Drugmaker Sued for…Overpaying for Drugs? Lawsuit Ushers in Expected Wave of Welfare Fiduciary Litigation

The first complaint was filed in what is expected to be a wave of litigation alleging breach of fiduciary duty in selecting and monitoring welfare plan vendors. While the facts of this particular case may make it somewhat...more

Courts Continue to Scrutinize Arbitration Clauses in ERISA Plans

Seyfarth Synopsis: A recent district court decision highlights the continued uncertainties about what it means to include an arbitration clause in an ERISA plan. While courts generally agree that such clauses are, in theory,...more

Seventh Circuit Rejects Plan’s Attempt to Compel Individual Arbitration of Participant’s Fiduciary Breach Claims

Seyfarth Synopsis: Recognizing that the Plan contained an unambiguous arbitration  provision, and that “ERISA claims are generally arbitrable,” the Seventh Circuit Court of Appeals nonetheless found that arbitration could not...more

The 10th Circuit’s New Interpretation of What is Mandated under ERISA’s Notice Requirements May have Far Reaching Effects On Plan...

Seyfarth Synopsis: A recent 10th Circuit decision holding that in order for the abuse of discretion standard to apply in litigation the claims administrator must provide participants with actual notice of discretionary...more

Ninth Circuit Rules that a Domestic Partner Under California State Law Was a Spouse for an ERISA Plan

In an unpublished decision dated May 16, 2019, the Ninth Circuit held that a plan administrator abused its discretion by denying surviving spouse benefits under an ERISA retirement benefit plan to a participant’s domestic...more

Plaintiffs Must Do More Than Claim A Breach of Fiduciary Duty to State An ERISA Claim

Seyfarth Synopsis: A recent case from the Eastern District of Pennsylvania reaffirms the basic principle that a threshold element of any ERISA claim is pleading the existence of an ERISA plan....more

Third Circuit Adopts Plan Friendly Interpretation Of A Mental/Nervous Limitation

Seyfarth Synopsis: In a win for ERISA plan and claims administrators, the Third Circuit has affirmed the broad enforcement of a long-term disability plan’s mental or nervous limitation period....more

Grounding Deferential Review in California – No Preemption for Discretionary Clause Ban

Seyfarth Synopsis: In a decision with wide ranging implications, the Ninth Circuit has ruled that a discretionary clause in an employer drafted plan document is subject to, and invalidated by, California’s insurance...more

Eighth Circuit Jimmies The Lid On Pandora’s Box

Seyfarth Synopsis: In an opinion that may result in increasingly complex ERISA benefits litigation, the Eighth Circuit has allowed a breach of fiduciary duty claim premised on alleged faulty claims handling practices to...more

Fifth Circuit: Discretionary Ban Does Not Mandate De Novo Review

In Ariana M. v. Humana Health Plan of Texas, Inc., No. 16-20174 (5th Cir. Apr. 21, 2017), the Firth Circuit concluded that Texas’ ban on discretionary clauses in certain insurance policies did not require a de novo review of...more

Administrative Exhaustion As a Defense to Statutory ERISA Claims?  Not So Much

Seyfarth Synopsis: The Sixth Circuit becomes the seventh circuit court to not require administrative exhaustion for statutory ERISA claims (as opposed to denial of benefit claims), while two circuit courts still do. In...more

Does the Fiduciary Exception Apply to Legal Advice Received By Insurers During the Claims Process

Seyfarth Synopsis: Adding to the body of conflicting authority on the scope of the attorney-client privilege in ERISA lawsuits, a district court has found that the fiduciary exception to attorney-client privilege applies to...more

Court Smacks Down Plaintiff’s “[But Mom…] Everyone Else Is Doing It” Public Policy Argument To Void Illegal Exclusions Provisions

Seyfarth Synopsis: A Court ruled that under the Affordable Care Act, an ERISA governed plan exclusion cannot unequivocally bar emergency medical care related to injuries sustained in a fireworks explosion. Recently, a...more

Watching SCOTUS – ERISA Church-Plan Exemption Revisited

Seyfarth Synopsis: Currently before the Supreme Court are two petitions regarding the thorny legal question of which organizations can qualify for ERISA’s Church-plan exemption. If the Supreme Court grants certiorari and...more

Don’t Be a Menace to South Central (Houston Action Council) When Your ERISA Claim Is No Good

Seyfarth Synopsis: A recent decision district court ruling affirms that in a benefit discrimination claim, just as in a typical claim of employment discrimination, to survive summary judgment a plaintiff must demonstrate that...more

Supreme Court Concludes That ERISA Preempts State Reporting Requirements

In a closely observed federalism battle over the scope of ERISA preemption, the Supreme Court came down on the side of Federal power. Specifically, in Gobeille v. Liberty Mutual Insurance Company, the Court, in a 6-2 ruling,...more

The Magic 8 Ball Says – The Supreme Court’s Montanile Decision and The Seemingly Random Evolution of Supreme Court ERISA Remedies...

It’s a common fact pattern. A plan participant is injured and received benefits for treatment of his injuries. The participant then sues a third party for damages based on his injuries. The plan then seeks to recover a...more

Same-Sex Marriage Bans As Sex Discrimination: The Potential Impact On Plan Sponsors And Employers

In last week’s oral argument on the constitutionality of same-sex marriage bans, Chief Justice Roberts asked the following question: Counsel, I’m not sure it’s necessary to get into sexual orientation to resolve the...more

Same-Sex Marriage Bans As Sex Discrimination: The potential impact on plan sponsors

In last week’s oral argument on the constitutionality of same-sex marriage bans, Chief Justice Roberts asked the following question: Counsel, I’m, I’m not sure it’s necessary to get into sexual orientation to resolve...more

The Supreme Court Weighs The Constitutionality Of Restricting Marriage To Opposite Sex Couples, And The Impact Their Decision May...

Background - Today, the U.S. Supreme Court heard oral argument on two questions regarding the Constitutionality of state laws limiting marriage to opposite-sex couples. In 2013, the Supreme Court side-stepped the issue...more

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