Stewart v. Hartford Life & Accident Ins. Co., No. 21-11919, __ F.4th __, 2022 WL 3221296 (11th Cir. Aug. 10, 2022) (Before Circuit Judges Newsom, Tjoflat, and Hull).
Courts typically review ERISA benefit decisions under one of two standards: either de novo, i.e., with no deference to the benefit claim administrator, or for
Harris v. Lincoln Nat’l Life Ins. Co., No. 21-13186, __ F.4th __, 2022 WL 3009199 (11th Cir. July 29, 2022) (Before Circuit Judges Jordan and Rosenbaum, and District Judge John Steele).
ERISA is very specific about some things, but on others it is famously vague. For example, ERISA says that plan participants are allowed to bring a civil action for benefits, but it doesn’t give much guidance as to how the courts should handle those actions. Are they handled the same way as other civil cases under the Federal Rules of Civil Procedure? Do claimants have the right to a jury? What standard of review should the courts use?
Continue Reading Eleventh Circuit Holds That De Novo Review Requires Courts to Consider All Relevant Evidence, Regardless of Whether It Was Submitted to a Claim Administrator
Williams v. Wright, No. CV BPG-21-2076, 2022 WL 2818949 (D. Md. July 19, 2022) (Magistrate Judge Beth P. Gesner).
This decision involves the third of three related lawsuits between certain members of the wealthy duPont family and their household employees regarding the employees’ entitlement to retirement benefits. To properly understand this suit under ERISA’s anti-retaliation provision, you have to go back to the first suit and its history, which actually begins in 1947.
Continue Reading Plan Participant States a Claim That She Was Sued for Seeking Plan Benefits