"Stern's holding that the employer was not acting as an ERISA fiduciary in connection with the challenged conduct is a key victory for employers. Navarro II and Lewandowski II did not address whether the challenged conduct was subject to ERISA's fiduciary standards because those courts dismissed the plaintiffs' claims for lack of Article III standing.... Stern's application of the 'meaningful benchmark' standard to a health plan is an important development that may impact whether plaintiffs in future cases alleging excessive health plan costs can plausibly allege a claim for relief." [Stern v. JPMorgan Chase & Co., No. 25-2097 (S.D.N.Y. Mar. 9, 2026)]  MORE >>