When an ERISA Beneficiary Change by Phone Call Fails: N.D. Alabama Enforces the Plan's Written-Designation Requirement and Voids a Bigamous MarriageIn 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.
ERISA Long-Term Disability Denial Upheld: Eighth Circuit Affirms Unum Termination Where Treating Doctor's Own Records Supported Sedentary WorkIn 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.
Fifth Circuit Affirms Summary Judgment for MetLife on De Novo Review, Holding LTD Claimant Was Not Totally Disabled and Declining to Resolve Choice-of-Law Dispute Over Dueling State Bans on Delegation ClausesIn 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.
Third Circuit Vacates Dismissal of Hospitals’ ERISA Underpayment Claims Under MRC-1 and MRC-2 PlansIn 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.
When Can an ERISA Claimant Get Discovery Beyond the Administrative Record? Court Allows Targeted Conflict-of-Interest Discovery in Long COVID Disability CaseIn 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.
An ERISA “Any Occupation” Denial Survives Despite Insurer’s Vocational GapsIn 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.
When Does ERISA Preempt State Law Claims for a Voluntary Accident Policy? an Oklahoma Court Weighs InIn 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.
Prove You Mailed It: Northern District of Illinois Dismisses ERISA Disability Suit for Failure to Exhaust After Claimant Cannot Establish He Sent His AppealIn 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.
N.D. Cal. Reinstates ERISA Disability Benefits Despite Normal Cognitive Test ScoresIn 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 Defeats Unum’s Attempt to Move ERISA Disability Case: Court Keeps Long-Term Disability Claim in Plaintiff’s Chosen ForumRoberts 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.
ERISA Reaches Overseas: Court Holds ERISA Preempts State-Law Benefit Claims by Foreign Workers Injured AbroadAjeti 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.
ERISA “Any Occupation” Standard Defeats MS Claimant: N.D. Illinois Court Upholds Unum’s Long-Term Disability Denial on De Novo ReviewIn 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.
When “Sedentary” Isn’t the Whole Job: California Court Restores 20 Years of ERISA Disability Benefits Reliance Standard Cut OffFollowing 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.
Third Circuit Revives Hospitals’ ERISA Underpayment Claims Against Cigna Under MRC-1 and MRC-2 PlansIn 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.
Third Circuit Revives ERISA Recovery and Fiduciary-Breach Claims Tied to Cigna’s MRC-1 Out-of-Network ReimbursementsIn 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
Eleventh Circuit Affirms De Novo Disability Denial but Questions Whether Plan Conferred DiscretionIn 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.
ERISA AD&D Denial Survives Exhaustion Challenge: Michigan Court Holds Plan Document, Not the SPD, Controls Claims ProceduresThe court denied Defendant Metropolitan Life Insurance Company’s motion.
Jeffrey Ahn v. Cigna Health and Life Insurance CoCourt of Appeals for the Third Circuit ·