"The employer actually deducted the premiums from the deceased's wages and then paid them to Unum for multiple years. Yet, the Court does not weigh this actual payment of premiums against the early written denial of coverage to determine whether, under ERISA or state insurance law, the coverage was valid. Nor does the Court explain why it considers the Summary of Benefits the controlling plan document that trumped the misrepresentations and the payment of the premiums." [Talasek v. National Oilwell Varco, L.P., No. 20-20069 (5th Cir. Oct. 19, 2021)]