BENEFITS DIGEST

The Supreme Court has declined to review the suit by 96 former Ruby Tuesday managers and executives against Regions Bank over their top-hat plan, a deferred-compensation arrangement for a select group of managers and executives that sits outside most of ERISA’s protections. The [Sixth Circuit](https://digest.theinnerfirm.com/docs/aldridge-v-regions-bank-opinion-2025-07-17.pdf) had rejected their state-law claims and the money remedy they sought, called a surcharge, in a dispute over accounts informally funded with corporate-owned life insurance. PLANADVISER also describes the government’s argument that the case was a poor vehicle for the broader question about equitable monetary relief under ERISA. The denial leaves the Sixth Circuit’s outcome in place without endorsing its reasoning.

A widower sued his late husband’s employer after discovering that the company had withheld life-insurance premiums matching the $300,000 coverage his husband elected while actually enrolling him for $50,000. In an October 13 [opinion](https://digest.theinnerfirm.com/docs/thomas-v-uacj-opinion-2026-10-13.pdf) Roberts Disability Law examines, Chief Judge Hala Jarbou of the Western District of Michigan denied default judgment for the remaining $250,000 because the plan unambiguously capped his coverage at $240,000 under its salary-based formula and required proof of good health for amounts over $100,000 that was never submitted. Premium withholding could not rewrite those written terms, and the court declined document-request penalties because no prejudice was shown. The takeaway for administrators is that enrollment systems and payroll need to match the plan, because deductions alone do not rewrite it.

Saul Ewing’s monthly roundup examines how courts evaluate disability evidence. A Massachusetts court rejected every argument a claimant raised against a benefits termination, including his attempt to rely on a physician report submitted nine months after the final appeal decision, which the court would not consider. A California court said an insurer need not take subjective complaints at face value. An Oregon court reinstated benefits for a claimant with young-onset Parkinson’s disease, crediting her personal statements and treating physicians over doctors who reviewed the records without examining her. The Eighth Circuit refused to credit a treating physician who said the claimant could do seated work for two years and changed his opinion only after benefits were terminated. And an Alabama dispute over who should receive life insurance proceeds went to the insured’s daughters, after the court found a telephonic beneficiary designation invalid under the policy and the purported marriage void, noting that federal courts routinely look to state law to identify a spouse under an ERISA plan.

Lockton runs one of the country’s largest insurance brokerages, and two of its employees now claim it put itself on both sides of its own benefits plan. Lockton sponsors its welfare plan and serves as the plan’s named fiduciary, and the complaint alleges it also installed itself as the plan’s broker. In that role, the suit says, Lockton picked the carriers for employee-paid products from life insurance to long-term disability, set its own commission and fee structure, and let carriers build that compensation into the premiums employees paid by payroll deduction. The complaint puts that compensation at $3.3 million from 2020 through 2024, drawn from the plan’s own government filings, with some fees routed through a benefits-communication firm Lockton fully acquired in 2025. The claims accuse Lockton of using its position to benefit itself at employees’ expense, and the relief sought includes repayment of the allegedly improper compensation and appointment of an independent person to oversee the plan. Capozzi Adler filed October 1 in Kansas City federal court, the latest in a wave of voluntary-benefits suits filed since December 2025. Lockton hasn’t yet responded in court.

After an employee died, his life insurer offered to reinstate his lapsed coverage if about $1,300 in back premiums were paid. His widow alleges that Taos Ski Valley declined the offer without telling her, and that she would have paid the premiums herself to preserve the $95,000 policy. Judge Kea Riggs allowed her claim seeking the lost insurance benefits to proceed, holding that ERISA's equitable remedies provision permits make-whole monetary relief against a fiduciary for this kind of breach, and that the remedy doesn't require tracing the money to any particular fund. The ruling decides only that the claim may go forward; an earlier theory failed against documents showing the employer answered a 2023 inquiry promptly. [Roberts Disability Law's analysis](https://robertsdisability.com/erisa-surcharge-against-an-employer-fiduciary-new-mexico-district-court-lets-a-lapsed-group-life-insurance-claim-proceed) flags the duty at the center: a fiduciary must share material information about coverage with the people it affects, even when no one asks.

A lead mechanic suffered a stroke at home, fell, struck his head, and died three days later. The autopsy called the death an accident caused by the fall, with the stroke contributing. His widow sought the accidental death benefit under the employer's group policy, which pays only for injuries independent of illness, and Hartford denied the claim because the fall followed an acute stroke. The court ruled for Hartford on September 25, concluding that the denial was correct even when reviewed independently. A medical examiner's finding that a death was accidental did not settle the insurance question, because this policy also required the injury to be independent of illness. Participants rarely learn that distinction until a claim, which makes it worth a line in benefits communications.

In Metropolitan Life Insurance Co. v. Williams, a General Motors life insurance participant tried to name a new beneficiary in a 2020 phone call to MetLife, and the court held the attempt failed because the plan required a signed written designation, with phone elections covering enrollment only. The court declined to apply substantial compliance, and under the plan's fallback provision the claimant could take only as a surviving spouse, a status the court rejected because her marriage to the participant was void under Georgia law while her prior marriage remained undissolved. The participant's daughters prevail, and the contrast with last week's Liu v. Kaiser is instructive. A requirement written into the plan gets enforced; a procedure that lives only in administrative practice does not.

In Halloran v. Unum Life Insurance Company of America, No. 25-2550, 2026 WL 2545315 (8th Cir. Aug. 28, 2026), a panel of Chief Judge Colloton and Circuit Judges Gruender and Kobes, with Judge Kobes writing, affirmed the termination of a claimant's ERISA long-term disability benefits. The slip opinion appears in Court Decisions above.

In Grice v. Metropolitan Life Insurance Company, No. 25-50566, 2026 WL 2519457 (5th Cir. Aug. 26, 2026), a per curiam opinion, the Fifth Circuit affirmed the district court's grant of summary judgment to Metropolitan Life Insurance Company in this ERISA action challenging the denial of long-term disability benefits.

In Hudson Hospital OPCO v. Cigna Health and Life Insurance Company, No. 24-2830 (3d Cir. Aug. 26, 2026), the Third Circuit vacated the dismissal of three New Jersey hospitals' ERISA claims that Cigna underpaid them under the plans' MRC-1 and MRC-2 reimbursement provisions, while affirming dismissal of their reasonable-and-customary and fiduciary-duty theories. The partial revival sends a long-running provider-payment dispute back for another round on the plan-terms claims.

In Mason v. New York Life Insurance Company, a magistrate judge in the Southern District of New York let a long COVID disability claimant pursue narrow discovery outside the administrative record, allowing targeted requests for the financial incentives and performance reviews of the employees who handled her claim while declining broader asks like aggregate denial-rate statistics. The takeaway: conflict-of-interest discovery fares better aimed at the specific people who decided the claim than framed as a search through the administrator's overall track record.

In Mead v. Life Insurance Company of North America, No. 8:24-cv-2756-TPB-AEP, 2026 WL 2444754 (M.D. Fla. Aug. 20, 2026), United States District Judge Tom Barber granted the insurer’s motion for summary judgment and denied the claimant’s cross-motion.

In Cregan v. Unum Life Insurance Company of America, No. 24-CV-340-DES, 2026 WL 2427920 (E.D. Okla. Aug. 19, 2026), United States Magistrate Judge D. Edward Snow addressed whether a voluntary accident policy offered through an employer falls under ERISA.

In Stempel v. Unum Life Insurance Company of America, No. 24 C 6077, 2026 WL 2241244 (N.D. Ill. Aug. 4, 2026), the court dismissed an ERISA disability suit for failure to exhaust administrative remedies after the claimant could not establish that he actually mailed his appeal.

In O’Connor v. Metropolitan Life Insurance Company, No. 4:24-cv-08723-YGR, 2026 WL 2220173 (N.D. Cal. July 29, 2026), Chief United States District Judge Yvonne Gonzalez Rogers granted Plaintiff’s motion for judgment under Federal Rule of Civil Procedure 52 and denied Defendant’s cross-motion.

Roberts Disability Law, P.C. secured a procedural win for its client in Goldman v. Unum Life Insurance Company of America, No. 3:26-cv-01022-LJC, —F.Supp.3d—-, 2026 WL 2184768 (N.D. Cal. July 21, 2026), where United States Magistrate Judge Lisa J.

Ajeti v. Life Insurance Company of North America, No. 26-3249, 2026 WL 2150163 (E.D. Pa. July 27, 2026), addresses whether ERISA governs, and preempts, state-law claims brought by foreign nationals seeking disability benefits under a plan established by their American employer.

In Scorzo v. Unum Life Insurance Company of America, No. 23-cv-3836 (N.D. Ill. July 17, 2026), the court upheld Unum’s denial of long-term disability benefits under the any-occupation standard on de novo review.

Following a bench trial on the administrative record, a California federal court found in favor of a long-term disability claimant whose ERISA benefits Reliance Standard Life Insurance Company had paid for two decades before cutting them off.

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 claims they brought against Cigna Health and Life Insurance Company and Connecticut General Life Insurance Company under ERISA.

In Advanced Gynecology & Laparoscopy of North Jersey P.C. v. Cigna Health & Life Insurance Co., No. 24-2212, 2026 WL 2030368 (3d Cir. July 13, 2026), nearly two dozen New Jersey healthcare practices, providing out-of-network services to Cigna subscribers who had assigned their plan benefits, alleged that Cigna

In Wang v. Metropolitan Life Insurance Co., No. 25-11527, 2026 WL 1960673 (11th Cir. July 7, 2026), the Eleventh Circuit affirmed the entry of judgment for MetLife on a pro se participant’s ERISA claim for long-term disability benefits under a General Electric plan.

The court denied Defendant Metropolitan Life Insurance Company’s motion.

Court of Appeals for the Third Circuit ·