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Tag Archives: ERISA

Labor & Employment – ERISA ‘Satisfactory Proof’ Standard Clarified (access required)

Cosey v. The Prudential Ins. Co. of America : Joining five sister circuits, the 4th Circuit says an ERISA plan that grants long-term disability benefits on proof of continuing disability “satisfactory” to the plan administrator does not confer discretionary decision-making authority on the plan administrator; the 4th Circuit vacates summary judgment for employer and remands employee’s suit for disability benefits for her fibromyalgia, sleep disorder and related conditions.

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Insurance – Life – Labor & Employment – ERISA – Equitable Relief – Breach of Fiduciary Duty (access required)

McCravy v. Metropolitan Life Ins. Co. A bank employee who paid for life insurance for her daughter through her employee benefit plan, but who was denied insurance benefits when her 25-year-old daughter died, has her claim for “equitable relief” for the insurance carrier’s breach of fiduciary duty reconsidered by the 4th Circuit, in light of CIGNA Corp. v. Amara, 131 S. Ct. 1866 (2011).

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Labor & Employment – ERISA — Civil Practice – Subject Matter Jurisdiction – Remand to Plan Administrator — Collateral Order Doctrine (access required)

Dickens v. Aetna Life Ins. Co. The 4th Circuit dismisses for lack of subject matter jurisdiction a plaintiff’s ERISA suit challenging termination of his long-term disability benefits; the district court order denying both parties’ motions for summary judgment and remanding the case to the plan administrator was not appealable under the collateral order doctrine.

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