Pizarro v. Home Depot, Inc., No. 22-13643, __ F.4th __, 2024 WL 3633379 (11th Cir. Aug. 2, 2024) (Before Circuit Judges Branch, Grant, and Carnes)

Your ERISA Watch is cheating a little in this edition, as our case of the week is not actually from last week, but the week before. Rather than relegate

Smith v. UnitedHealth Grp., No. 23-2369, __ F. 4th __, 2024 WL 3321646 (8th Cir. Jul. 8, 2024) (Before Circuit Judges Colloton, Erickson, and Kobes)

Cross-plan offsetting is a controversial practice – sometimes referred to as “self-help” for third-party administrators of healthcare plans and, alternatively, “robbing Peter to pay Paul” – to which plan