"The first church plan case to reach the federal appellate courts is being returned to the district court to consider a proposed settlement between the parties ... If the settlement is approved, this case will join the very first case in recent years to test the church plan exemption, Thorkelson v. Publ'g House of the Evangelical Lutheran Church in Am. ... as cases in which the district court ruled on the interpretation of the statute, but the parties settled before the court could rule." [Overall v. Ascension Health, No. 14-1735 (6th Cir. Mar. 17, 2015)]