News & Analysis as of

Breach of Contract Employee Benefits

Stikeman Elliott LLP

Status Update: Ontario Court Upholds RSU Forfeiture Provision, Despite Employment Agreement Violating the ESA

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In the recent Wigdor v Facebook Canada Ltd. and Meta Platforms, Inc., 2025 ONSC 4051 decision (the “Decision”), which has not yet been reported, the Ontario Superior Court of Justice upheld the enforceability of restricted...more

Polsinelli

Sixth Circuit Holds TPAs Do Not Get a Free Pass from ERISA’s Fiduciary Duties

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In a decision about ERISA’s fiduciary duties and transparency, the Sixth Circuit in Tiara Yachts, Inc. v. Blue Cross Blue Shield of Michigan held that Blue Cross Blue Shield of Michigan (BCBSM), a third-party administrator...more

Holland & Knight LLP

Supreme Judicial Court Clarifies Scope of Massachusetts Noncompetition Agreement Act

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The Massachusetts Supreme Judicial Court (SJC) has ruled that a forfeiture clause triggered by a breach of a non-solicitation agreement is not a "forfeiture for competition agreement" under the Massachusetts Noncompetition...more

King & Spalding

Appeals Court Revives Company’s Suit against Blue Cross for Breach of ERISA Fiduciary Duty

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On May 21, 2025, the Sixth Circuit revived a company’s lawsuit against Blue Cross Blue Shield of Michigan (BCBSM) for breaching its fiduciary duties under ERISA as a third-party administrator (TPA). The plaintiff company,...more

Holland & Knight LLP

Sixth Circuit Reverses Dismissal of ERISA Healthcare Fee Suit Against Third-Party Administrator

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There has been a recent rise in Employee Retirement Income Security Act of 1974 (ERISA) litigation against third-party administrators (TPAs) and other service providers challenging their management of self-funded health...more

Wiley Rein LLP

Fifth Circuit Holds Carve-Back Provision Could Not Overcome Breach of Contract Exclusion for Louisiana Wage Payment Act Claim

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The United States Court of Appeals for the Fifth Circuit, applying Louisiana law, has held that a breach of contract exclusion barred coverage for a judgment awarded to two employees who were not paid severance as required...more

Conn Maciel Carey LLP

CMC Attorney Mark Trapp Secures Favorable Ruling in $23M Pension Dispute

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In 2017, Consumers partially withdrew from the Central States, Southeast and Southwest Areas Pension Fund. The fund said the company owed $11.3 million (or monthly payments of $42,200 for 20 years) for its share of the fund’s...more

Bennett Jones LLP

BC Court of Appeal Confirms that the Duty of Honest Performance Does Not Extend to Pre-Contractual Dishonesty

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In Ocean Pacific Hotels Ltd. v Lee, 2025 BCCA 57, the Court of Appeal for British Columbia confirmed that the duty of honest performance in contract does not extend to pre-contractual negotiations....more

Keating Muething & Klekamp PLL

Benefits Monthly Minute - March 2025

The March Monthly Minute brings you three recent case updates addressing 401(k) forfeiture utilization, TPA responsibility for recovering self-insured plan’s fraudulently paid claims, and continued PBM litigation in the wake...more

Carlton Fields

California Appellate Court Agrees Marijuana Delivery Driver’s Accident Not Covered Under Personal Auto Policy

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A California Court of Appeals decision brought one auto policyholder decidedly down from “cloud nine” in Murphy v. AAA Auto Insurance of Southern California, which found no coverage over a cannabis delivery service employee’s...more

Littler

Ontario, Canada Appeal Court Dismisses Employer’s Appeal of $1.8 Million Damage Award to Retired VP

Littler on

In Boyer v. Callidus Capital Corporation, 2025 ONCA 79, the Court of Appeal for Ontario (OCA) dismissed the employer’s appeal of the motion judge’s order in Boyer v. Callidus, 2024 ONSC 20, discussed in detail here. The...more

Farrell Fritz, P.C.

The Importance of Filing a Notice of Claim Against A Village: CPLR 9802 - A Trap for the Unwary Litigator

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Failing to file a notice of claim pursuant to Civil Practice Law and Rules (“CPLR”) Section 9802 can become a trap for the unwary litigator who commences a hybrid proceeding-action (Article 78 claim(s) combined with plenary...more

Bradley Arant Boult Cummings LLP

How to Prevent a Lawsuit Over Retirement Plan Forfeitures

There has been a rash of lawsuits recently challenging how forfeitures are used in retirement plans. (Forfeitures are the amounts remaining when the unvested portion of a participant’s account is forfeited.) The novel theory...more

Robinson+Cole ERISA Claim Defense Blog

Ninth and Second Circuit Courts of Appeals Rule that Preauthorization Process Does Not Impose Independent Contractual Liability on...

Within days of one another, the U.S. Court of Appeals for the Ninth and Second Circuits ruled—on issues of first impression for both—that ERISA expressly preempts state law breach of contract and promissory estoppel claims...more

Carlton Fields

Ringmaster’s Review: Fall 2023 Litigation on Parade

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In Ross v. Venerable Insurance & Annuity Co., a Missouri appellate court reversed judgment in favor of the named beneficiary of a flexible premium deferred annuity contract. Following the annuitant’s death, the beneficiary...more

Carlton Fields

Expect Focus - Volume III, September 2023

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Regulators Hit Jackpot: Off-Channel Communications - Several years before announcing the first “off-channel” communications enforcement action, the SEC and FINRA cautioned broker-dealers and investment advisers about...more

Saul Ewing LLP

The Friday Five: Five Current ERISA Litigation Highlights - April 2022

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This month’s Friday Five covers cases relating to: (1) whether claim administrators can recover overpayments through a breach of contract claim under state law; (2) whether claim administrators can rely solely on a claimant’s...more

Epstein Becker & Green

Third Circuit: Provider’s Out-of-Network Claims not Pre-empted by ERISA

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In an important win for healthcare providers, on July 17, 2020, the Third Circuit determined in a published opinion that an out-of-network provider’s direct claims against in insurer for breach of contract and promissory...more

Rivkin Radler LLP

Employee Benefit Plan Review – From the Courts

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Second Circuit Affirms Decision Rejecting ERISA Claims for Retiree Health Benefits The U.S. Court of Appeals for the Second Circuit has affirmed a district court’s decision dismissing claims under the Employee Retirement...more

Proskauer - Employee Benefits & Executive...

Best Practices in Administering Benefit Claims #9 – Managing Litigation Utilizing a Plan’s Litigation Tools

As we shifted focus last week from a plan’s administrative claims procedures to defending against a claim for benefits in court, we explained how a well-documented administrative record can enhance the chances of getting a...more

Seyfarth Shaw LLP

Out Of Network Provider’s Claim Against Health Insurer Avoids ERISA Preemption

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Seyfarth Synopsis: A provider that is not seeking benefits based upon an assignment of a patient’s claims under ERISA but instead is pursuing state law claims based solely on agreements and representations made directly by...more

Blake, Cassels & Graydon LLP

Pensions Newsletter – October 2018

Welcome to the 22nd issue of the Blakes Pensions Newsletter. This newsletter provides a summary of recent jurisprudential developments that affect pensions and benefits and is not intended to be legal advice....more

King & Spalding

Fifth Circuit Reverses District Court’s Ruling that Required Hospital to Plead Specific Plan Language to State a Claim For ERISA...

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On June 12, 2018, the United States Court of Appeals for the Fifth Circuit issued a ruling in Innova Hospital San Antonio, L.P. v. Blue Cross and Blue Shield of Georgia, Inc., et al. that clarified the scope of what a...more

Seyfarth Shaw LLP

Central District Of California Finds No ERISA Preemption Where Determination Of Benefits At Termination Is Non-Discretionary

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Seyfarth Synopsis: Claims for benefits at termination may proceed as a breach of contract claim in state court, and avoid ERISA preemption, where the calculations are individualized, straightforward and do not implicate an...more

Holland & Knight LLP

Religious Institutions Update: January 2018 - Lex Est Sanctio Sancta

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Timely Topics - By Shannon B. Hartsfield - The U.S. Department of Health and Human Services (HHS) announced on Jan. 18, 2018, the creation of a new division within its Office for Civil Rights (OCR). OCR is described as...more

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