As expected, the last week of 2025 was a slow one in the federal courts, but there were some interesting ERISA cases nonetheless. Read on to learn about (1) yet another dismissal of a putative class action alleging fiduciary breaches over the use of forfeited plan contributions (Donelson v. Meijer), (2) an employer and an insurer unsuccessfully attempting to dismiss claims against them in a disability dispute (Hamilton v. Logic20/20), (3) a win for plaintiffs in a medical benefit case involving residential mental health treatment (Michelle Z. v. California Physicians’ Service), and (4) a case in which an employee claims skullduggery in the administration of an employee stock ownership plan, but confusingly refuses to allege any claims under ERISA (Botterio v. Tessel). We hope you have an enjoyable New Year’s Eve, and we’ll see you in 2026.
Below is a summary of this past week’s notable ERISA decisions by subject matter and jurisdiction.
Breach of Fiduciary Duty
Sixth Circuit
Donelson v. Meijer, Inc., No. 1:25-CV-1156, 2025 WL 3754241 (W.D. Mich. Dec. 29, 2025) (Judge Hala Y. Jarbou). The plaintiffs in this putative class action are participants in the 401(k) retirement plan of midwestern supercenter chain Meijer, Inc. The plan’s assets are held in a trust fund administered by Meijer, which makes base contributions and matches 50% of employee contributions up to a limit. Employees must work for five years to receive full matching contributions; otherwise, the funds are forfeited to the general trust. The plan allowed Meijer to use forfeitures to pay administrative expenses or reduce employer contributions. From August 2019 to January 2025, Meijer used forfeitures solely to reduce employer contributions. In January 2025, the plan was amended to prioritize reducing employer contributions with forfeitures. Plaintiffs brought this action under ERISA, alleging that Meijer’s use of forfeited funds to reduce its contribution obligations breached its duties of loyalty and prudence, and that it engaged in prohibited transactions. Meijer moved to dismiss. If you are a loyal reader of Your ERISA Watch, the court’s ruling will not surprise you; it granted the motion in full. On the duty of loyalty, plaintiffs contended that Meijer should have used forfeitures to aid beneficiaries or defray administrative costs. Meijer responded that its duty was to provide promised benefits, and using forfeitures for administrative expenses was not promised. The court agreed with Meijer, ruling that “a fiduciary’s duties are only to provide beneficiaries the specific benefits promised in the plan.” The court stated, “Just as fiduciaries managing a defined benefit plan need only provide beneficiaries the monetary payment they were promised, fiduciaries managing a defined contributions plan need only provide beneficiaries the money in their individual accounts. And § 1002(34) recognizes that employees may be entitled to funds forfeited by others, but only if those forfeitures are allocated to their individual accounts. Before that happens, employees are not entitled to others’ forfeited funds.” In the end, “Meijer promised nothing regarding forfeitures, leaving that decision entirely to the discretion of the fiduciary. And because Meijer made no promises regarding forfeitures, it did not violate its fiduciary duties.” The court noted that “[t]his holding aligns with the significant majority of courts across the country that have considered similar claims,” as well as “with the long-held position of the United States Department of Treasury that forfeitures in defined contribution plans may be used to reduce employer contributions.” The court next considered plaintiffs’ prohibited transactions claim. Meijer argued that using forfeitures to reduce contributions was not a “transaction,” but the court did not even reach this issue, concluding that “the provisions of ERISA that limit an employer’s ability to benefit from a fiduciary’s actions are inapplicable when the employer could achieve the same benefit via plan amendment. Thus, because Meijer could have implemented an amendment requiring forfeitures to go toward employer contributions, it could also achieve that same outcome by acting as a fiduciary without violating ERISA.” Finally, the court addressed plaintiffs’ argument that “Meijer violated its fiduciary duty of prudence by failing to use the forfeitures within the calendar year that they accumulated.” The plan allowed allocation by the following year, and IRS guidance required allocation, rather than use, by year’s end. The court found no violation of the plan or IRS guidance because the delay at issue was not unreasonable, and thus Meijer was not imprudent. As a result, the court granted Meijer’s motion and dismissed the action.
Disability Benefit Claims
Ninth Circuit
Hamilton v. Logic20/20, Inc., No. C24-916RSL, 2025 WL 3754023 (W.D. Wash. Dec. 29, 2025); Hamilton v. Logic20/20, Inc., No. C24-916RSL, 2025 WL 3754065 (W.D. Wash. Dec. 29, 2025) (Judge Robert S. Lasnik). Alexis Hamilton began working as a customer success consultant for Logic20/20 in 2019 when she was 25 years old. She alleges she was advised by Logic20/20 not to sign up for benefits until her 26th birthday because she was covered under her parents’ insurance plans until then. However, this delay triggered a requirement for her to complete an evidence of insurability (EOI) form under Logic20/20’s employee disability coverage, as more than 31 days had elapsed since her initial eligibility for enrollment. Hamilton contends that she would not have knowingly forgone automatic enrollment in disability benefits because of her history of ankylosing spondylitis. Eight months after beginning work, Hamilton received and completed her enrollment paperwork. She alleged she signed up for all available insurance, including short-term disability (STD) insurance. She believed she had also signed up for long-term disability (LTD) insurance, but Logic20/20 allegedly failed to provide her with an EOI form. She was not enrolled in LTD coverage in 2019 or 2020 and was not charged premiums for it during that period. In March 2020, after attempting to enroll in LTD benefits, she was informed by Logic20/20 to send an EOI form to Prudential, which she did not submit. In late 2020, Logic20/20 moved to online benefits enrollment, and Hamilton checked the box for LTD insurance, believing it was a continuation of her prior insurance. Logic20/20 and Prudential accepted her enrollment and began charging her premiums for LTD coverage, which it accepted until she stopped working at Logic20/20 in 2023 due to symptoms of long COVID which aggravated her preexisting conditions. She received the maximum amount of STD benefits from Prudential, but when she submitted a claim for LTD benefits, Prudential denied it due to the lack of an EOI form. Appeals were unsuccessful so she brought this action naming both Logic20/20 and Prudential as defendants. Against Logic20/20 Hamilton asserted a claim for breach of fiduciary duty and a claim for failure to provide plan documents, and against Prudential Hamilton asserted a claim for plan benefits and a claim for breach of fiduciary duty. Both defendants filed motions to dismiss, which were decided in the two orders cited above.
In its motion, Logic20/20 argued: (1) Hamilton had no standing; (2) Hamilton’s claims were time-barred; (3) Hamilton could not seek attorney’s fees; (4) Hamilton sought improper remedies; (5) Hamilton engaged in duplicative pleading; (6) Logic20/20 was not a fiduciary and did not breach any duty; and (7) Hamilton sought inappropriate equitable relief. The court rejected all of these arguments. It ruled that (1) plan participants have standing to sue, and ERISA includes in the definition of “participant” a former employee like Hamilton who has a colorable claim for benefits; (2) Hamilton’s claim was not time-barred because she plausibly alleged she did not have actual knowledge of Logic20/20’s breach of fiduciary duty until 2022; (3) ERISA authorizes awards of attorney’s fees for breach of fiduciary duty; (4) Hamilton sought relief through waiver, estoppel, reformation, and surcharge, which are all authorized equitable remedies under ERISA; (5) plaintiffs are allowed to plead simultaneous claims for plan benefits and equitable relief under ERISA; (6) Logic20/20 was plausibly a fiduciary because it was the plan sponsor and administrator, engaged in recordkeeping and enrollment, and collected premiums, and arguably breached its duty by misleading Hamilton as to the plan’s EOI requirements; and (7) Hamilton adequately pleaded facts supporting her equitable relief based on the alleged misrepresentations and deductions of premiums by Logic20/20. The court also allowed Hamilton’s claim for failure to produce plan documents to proceed because she alleged she had requested them from Logic20/20 in 2022 and never received them. Thus, the court denied Logic20/20’s motion to dismiss in its entirety.
As for Prudential, in its motion it argued that Hamilton could not bring a claim for plan benefits because she “admits that she did not meet the terms for LTD coverage under the plan,” i.e., she did not submit the required EOI form. The court agreed with Hamilton, however, comparing her situation favorably to that of the plaintiff in Salyers v. Metropolitan Life Ins. Co., in which the Ninth Circuit concluded that the defendants’ actions “were collectively ‘so inconsistent with an intent to enforce’ the evidence of insurability requirement as to ‘induce a reasonable belief that [it] ha[d] been relinquished.’” As a result, the court concluded that Hamilton had plausibly stated a claim for plan benefits. The court also concluded that she had pled a claim for breach of fiduciary duty against Prudential by alleging it failed to notify her of her lack of eligibility, misleading her as to her coverage by accepting premiums, and “using a compartmentalized system to escape responsibility.” Finally, the court denied Prudential’s motion to strike certain allegations in Hamilton’s complaint about Prudential’s 2023 settlement with the Department of Labor (DOL) over its denials of coverage for lack of EOI. The court found these allegations “both material and pertinent, in that the matter both relates and pertains to the type of practice alleged here.” The court also granted Hamilton’s request for judicial notice of documents relating to the DOL settlement and two court orders in a case with similar issues. As a result, both Logic20/20 and Prudential left the court empty-handed and all of Hamilton’s claims for relief against them will proceed.
Discovery
Third Circuit
Stallman v. First Unum Life Ins. Co., No. CV 23-20975 (JXN)(LDW), 2025 WL 3749611 (D.N.J. Dec. 29, 2025) (Judge Julien Xavier Neals). Jeremy Stallman was an attorney at Kasowitz, Benson & Torres LLP and covered under its various ERISA-governed employee benefit plans. He fractured his hip in September of 2019 and applied for and received short-term disability (STD) benefits. He was cleared to return to work in November of 2019 but filed a new claim for long-term disability (LTD) benefits based on symptoms from depression shortly thereafter, in January of 2020. The insurer and administrator of the LTD plan, First Unum Life Insurance Company, denied his claim, stating that the medical evidence did not support a disability and that Stallman was not covered under the policy as of November 2019. After exhausting administrative appeals, Stallman initiated this lawsuit. He moved to compel discovery, seeking (1) to include his STD claim file in the administrative record, (2) limited discovery on the completeness of the record, (3) extra-record discovery into First Unum’s alleged conflict of interest, and (4) discovery related to First Unum’s affirmative defenses. The assigned magistrate judge granted in part and denied in part Stallman’s motion, excluding the STD claim file from the administrative record for the LTD claim but allowing limited discovery regarding the completeness of the administrative record and the structural conflict of interest by First Unum. Stallman appealed parts of that decision to the district judge, who upheld it in this order. The district judge found that the arbitrary and capricious standard of review applied because First Unum was granted discretionary authority to determine benefit eligibility under the plan. Therefore, review was limited to the administrative record before First Unum at the time of the benefits determination. The court ruled that “while Plaintiff’s STD benefits were known to Defendant, the record does not reflect that the STD claim file was relied upon, submitted, considered, or generated in the course of making the LTD benefits determination at issue here.” The court pointed out that the medical basis for Stallman’s STD claim was different from the basis for his LTD claim. Furthermore, “Plaintiff fails to point to anything determinative in the administrative record produced by First Unum to indicate that the LTD claim administrator considered the STD file.” Instead, the LTD file merely “acknowledges the STD claim’s existence, which is insufficient to render it part of the administrative record.” As for Stallman’s request for conflict-of-interest discovery, the court noted that “[w]hile the Third Circuit has not adopted a standard for determining whether conflict of interest discovery may be pursued,” the magistrate judge “correctly noted that courts in this District have consistently required plaintiffs to identify a reasonable basis to suspect that a conflict influenced the benefits determination.” The court agreed with the magistrate judge that Stallman failed to demonstrate procedural irregularities or evidence of misconduct beyond the structural conflict inherent in First Unum’s dual role as claim payor and adjudicator. The magistrate judge did allow limited discovery on this issue, permitting one interrogatory to address whether the compensation or performance evaluations of First Unum’s claims and medical personnel involved in Stallman’s LTD claim decision were based on the outcome of their claims determinations. The district judge ruled that this was not an abuse of discretion. As a result, the court denied Stallman’s appeal in its entirety.
ERISA Preemption
Second Circuit
Botterio v. Tessel, No. 24-CV-4401-SJB-ST, 2025 WL 3718713 (E.D.N.Y. Dec. 23, 2025) (Judge Sanket J. Bulsara). Denise Botterio worked for Lambro Industries, Inc. for about 30 years and owned shares in the company. She filed this action in state court on behalf of herself and derivatively on behalf of the Lambro employee stock ownership plan (ESOP) against Lambro CEO David Tessel, asserting three state law causes of action: accounting, breach of fiduciary duty, and abuse of control. In her complaint, Botterio alleged that Tessel engaged in misconduct in his management of the ESOP. She claimed this misconduct led to the liquidation of the ESOP at an artificially depressed value. She alleged Tessel engaged in self-dealing, conflicts of interest, and a breach of fiduciary duty, asserting that Tessel favored the majority shareholder’s interests over those of the ESOP. Tessel removed Botterio’s action to federal court on ERISA preemption grounds. After discussions with Tessel and the court, Botterio amended her complaint twice, but continued to allege only state law claims for relief and did not add any claims under ERISA. Tessel filed a motion to dismiss, which was decided in this order. The court observed that even though Botterio’s claims were centered on an employee benefit plan, she had alleged no claims under ERISA. Botterio argued that her breach of fiduciary duty claim was sufficient to invoke ERISA: “Her position is that if a complaint intentionally pleads common law claims, so long as the factual allegations are sufficient, the Court can and should interpret the claims as ERISA claims.” The court found this “unpersuasive.” It explained that Botterio’s second amended complaint did not indicate an intent to bring an ERISA claim, did not give notice to Tessel that she was bringing such a claim, and Botterio’s conduct throughout the litigation demonstrated that she did not intend to pursue an ERISA claim. “Ultimately, there are limits on the ability to construe a complaint as alleging causes of action not actually pled. Here, Botterio filed three separate federal court complaints after being told that Tessel viewed her claims as preempted by ERISA. And at each turn, she refused to allege an ERISA claim, and as noted above, resisted – and did not accede to – any attempt to reframe her claim as a federal one.” As a result, the court refused to recharacterize Botterio’s claims as ERISA claims. The court then applied the Supreme Court’s two-pronged Davila test to determine if her state law claims were preempted. It ruled that they were. It found “the first prong is satisfied because Botterio could have brought this claim under ERISA, which empowers a plan participant to sue, on behalf of the plan, for a breach of fiduciary duty.” As for the second prong, “the breach of fiduciary duties owed to ESOP participants is not ‘completely independent’ from the ‘ERISA-related basis for legal action’…since ERISA creates the very fiduciary duties that Botterio alleges were breached. In other words, Botterio is seeking to vindicate a duty protected by ERISA, not one independent of the statute.” Thus, both prongs were satisfied and the court ruled that Botterio’s state law claims were completely preempted by ERISA. Additionally, Tessel requested to seal the unredacted filing of his motion to dismiss, which included a valuation report conducted by an external firm for Lambro. The court granted the motion to seal, finding that the commercial interests in keeping sensitive financial information confidential outweighed the public’s interest in disclosure. Finally, the court denied Botterio further leave to amend because she had already “had three chances to plead an ERISA claim that survives dismissal” and failed to do so.
Medical Benefit Claims
Ninth Circuit
Michelle Z. v. California Physicians’ Service, No. 23-CV-05784-AMO, 2025 WL 3731841 (N.D. Cal. Dec. 26, 2025) (Judge Araceli Martínez-Olguín). Plaintiffs Michelle Z. and Bo Z. are parents of A.Z., and all three are beneficiaries of health benefit plans administered by defendant California Physicians’ Service, d/b/a Blue Shield. Unfortunately, A.Z. has a history of mental health issues, including suicide attempts, and has required significant mental health treatment. In 2019, A.Z. received treatment at Evolve Growth Initiatives in California and later at Elevations Residential Treatment Center in Utah. Under plaintiffs’ original plan, which was an individual and family plan not governed by ERISA, Blue Shield initially approved coverage for A.Z.’s treatment at Evolve but denied coverage for treatment at Elevations, stating that out-of-state benefits were not included under the plan. In 2020, A.Z. was admitted to New Haven Residential Treatment Center in Utah. Claims for this treatment were also administered by Blue Shield, although many of them were adjudicated under a different ERISA-governed plan. Blue Shield denied coverage for this treatment as well, this time citing a lack of medical necessity, contending that A.Z.’s treatment at New Haven could have been provided in a less restrictive outpatient setting. Plaintiffs originally filed their complaint in state court, asserting claims for breach of contract and breach of the covenant of good faith and fair dealing. Blue Shield removed the case to federal court, after which plaintiffs added a cause of action for plan benefits under ERISA. The parties then filed cross-motions for judgment on the ERISA-governed benefits, and cross-motions for summary judgment on the state-law-governed benefits.
Addressing the state law claims first, the court at the outset denied plaintiffs’ request for additional discovery under Federal Rule of Civil Procedure 56(d) due to procedural deficiencies and a lack of diligence in pursuing discovery. As for the merits, “The principal dispute relevant to Plaintiffs’ breach of contract claim is about whether Plaintiffs obtained prior authorization.” Plaintiffs contended that they were prevented from obtaining prior authorization and argued that even without it, they would still be entitled to coverage if the services were a covered benefit and medically necessary. The court examined the plan, which it interpreted as providing that prior authorization was required for all non-emergency mental health admissions, but failure to obtain it would not automatically result in denial of coverage unless the services were not a benefit of the plan or were not medically necessary. Under this interpretation, neither side was entitled to summary judgment because there were issues of fact to be determined. On plaintiffs’ side, the court concluded that a reasonable jury could find that A.Z.’s services should have been prior authorized or covered as medically necessary, while on Blue Shield’s side, the jury could conclude that the services were not medically necessary even if Blue Shield had determined that initial coverage existed. As for plaintiffs’ claim for breach of the covenant of good faith and fair dealing, the court found that the same factual disputes precluded summary judgment on this cause of action as well. The reasonableness of Blue Shield’s decision to withhold benefits was a question for the jury.
On plaintiffs’ ERISA claim, the court conducted a de novo review of the administrative record and found that plaintiffs were entitled to judgment. The court determined that the care A.Z. received at New Haven under the ERISA-governed plan was medically necessary. The court examined treatment records from New Haven which showed A.Z.’s ongoing struggles, including anxiety, depression, panic attacks, aggressive thoughts and urges, impaired social relationships, and thoughts of self-harm. The court concluded that this treatment was consistent with A.Z.’s presentation, and any lower level of care would not have safely managed A.Z.’s symptoms. The court thus granted plaintiffs’ cross-motion for judgment on their ERISA claim and denied Blue Shield’s motion. The court directed the parties to meet and confer on the appropriate amount of benefits due, attorney’s fees, and prejudgment interest, and to file a further case management statement addressing a trial date for the state law claims and the possibility of further settlement discussions.
Pension Benefit Claims
Ninth Circuit
Upchurch v. International Union of Painters and Allied Trades Indus. Pension Plan, No. 2:25-CV-1918 DC AC PS, 2025 WL 3718847 (E.D. Cal. Dec. 23, 2025) (Magistrate Judge Allison Claire). Joseph J. Upchurch contends that he has accrued over 29 years of credited service and more than 24 benefit units under the Northern California Glaziers, Architectural Metal and Glassworkers Pension Trust Fund. The Glaziers Plan has a reciprocal agreement with the International Union of Painters and Allied Trades Industry Pension Plan (IUPAT). This agreement requires the first qualifying plan, in this case, Glaziers, to initiate coordination of benefits with other signatory plans. Upchurch submitted pension plan applications to both plans. Upchurch alleges that while Glaziers eventually began paying benefits after a delay, IUPAT denied benefits, citing a lack of covered employment. Upchurch contends that IUPAT erroneously applied a “rehabilitation plan” adopted in January 2022 to deny him early retirement benefits, which he claims violates the reciprocal agreement. Upchurch brought this action pro se alleging three claims for relief: denial of benefits under ERISA § 502(a)(1)(B) against IUPAT, breach of fiduciary duty under ERISA § 404(a)(1) against Glaziers, and violation of the reciprocal agreement by both Glaziers and IUPAT. Upchurch sought an order compelling the defendants to pay all benefits owed and a declaration of his eligibility for benefits under the reciprocal agreement. Both defendants moved to dismiss. Glaziers argued that Upchurch did not have standing to sue it, and that he failed to state a claim, while IUPAT argued that Upchurch “fails to allege what benefits he is entitled to, because the Plan was correct to deny plaintiff benefits, and because the Reciprocal Agreement does not bar changes made by the Rehabilitation Plan.”
Addressing Glaziers’ motion first, the court ruled that Upchurch’s complaint did not establish standing for his breach of fiduciary duty claim “because he has not identified how, even if he were to prevail, the Glaziers Plan caused an injury that is redressable by a favorable decision from this court. The complaint does not plainly seek any benefits directly from Glaziers.” Furthermore, calculating benefits is not a fiduciary function, and thus “[i]t appears clear to the court that the crux of plaintiff’s claim is one for denial of benefits, not breach of fiduciary duty.” Upchurch contended at oral argument that “he does contend that Glaziers wrongfully denied him benefits for a finite period of time between his application date and Glaziers’ delayed approval date,” and the court allowed him to amend his complaint to reflect this allegation. As for the reciprocal agreement with IUPAT, the court found no breach of fiduciary duty because that agreement was not part of any plan. Also, Upchurch did “not explain how Glaziers violated the Reciprocal Agreement, which only requires that the signatory plans provide the information to one another, not to individual enrollees.”
As for IUPAT, the court denied its motion to dismiss Upchurch’s wrongful denial of benefits claim. IUPAT contended that Upchurch was not entitled to benefits because he was not an “Active Employee,” i.e., he had not earned 450 hours of service in covered employment in the three years before he filed his application. Upchurch acknowledged that he did not contribute to the plan during the relevant time period, but contended that he was operating a self-employed contracting business, and, under the terms of the IUPAT plan, he was not required to make contributions in order to receive service hours. The court examined the relevant definitions and provisions of the IUPAT plan and was “unconvinced by IUPAT’s argument.” It concluded that “it is not at all clear that plaintiff failed to qualify” for benefits pursuant to the terms of the IUPAT plan and therefore recommended denial of IUPAT’s motion on this ground. However, the court recommended dismissal of Upchurch’s breach of fiduciary claim against IUPAT regarding the reciprocal agreement for two reasons. First, this claim “ultimately makes the same claim (that he was wrongfully denied benefits by IUPAT) and seeks the same remedy as his wrongful denial of benefits claim (provision of benefits),” and thus his claim was duplicative. Second, although Upchurch claimed that the rehabilitation plan violated the reciprocal agreement, the court found that “the Rehabilitation Plan does not change how certain hours are recognized” and thus “it does not violate the Reciprocal Agreement. The court agrees that the Rehabilitation Plan does not obviously impact the Reciprocal Agreement. Accordingly, this portion of the complaint should be dismissed.” As a result, the magistrate judge recommended denial of Upchurch’s claims against both parties for violation of the reciprocal agreement, allowed his claim for benefits against IUPAT to proceed, and allowed him to amend his complaint to assert a denial of benefits claim against Glaziers.
Pleading Issues & Procedure
Sixth Circuit
Kosla v. Flex Technologies, Inc., No. 5:25-CV-00070, 2025 WL 3754029 (N.D. Ohio Dec. 29, 2025) (Judge John R. Adams). Stephen Kosla worked for Flex Technologies from May 2005 to September 2024. Kosla developed cancer in 2019, which went into remission but returned in 2023, necessitating work absences for treatment. He filed this action against Flex, alleging that after informing his employer of his advanced cancer in September 2024, he was demoted and subsequently terminated after requesting accommodations. When Kosla initially filed this case, he alleged claims of disability discrimination under the Americans with Disabilities Act (ADA) and Ohio law, failure to accommodate under the ADA and Ohio law, aiding and abetting discrimination, retaliation, Family and Medical Leave Act (FMLA) interference, and FMLA retaliation. However, at the end of the discovery period Kosla took the deposition of one of Flex’s sales managers and contended that he learned information during that deposition that supported additional claims against Flex. He filed a motion for leave to amend his complaint to add causes of action for retaliation and interference with benefits under ERISA. In this order, the court denied his motion. The court stated that Kosla had enough information to form the belief that his termination was due to medical costs as soon as he was terminated in 2024, based on a conversation with Flex’s former president in 2022 or 2023. Kosla testified during his deposition that during this conversation the president asked about Kosla’s wife and specifically “how many more surgeries Plaintiff’s wife was expected to undergo.” Kosla further testified that “this call was the only reason he believes Defendant Flex Technologies terminated him due to the costs of his cancer treatment.” Thus, the court ruled that the additional information obtained during the deposition was not necessary in order for Kosla to assert claims of ERISA retaliation and interference at the outset of the case. The court concluded, “The facts as presented here indicate Plaintiff was not diligent in his attempt to meet the requirements of the Court’s Case Management Conference Plan. He had enough information prior to filing this case to plead the ERISA claims of retaliation and interference. Accordingly, the Court finds he has not shown good cause for bringing additional claims or altering the scheduling order.”