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Fourth Circuit Sets New Rule for Interpreting QDROs

"The court ruled that QDROs are essentially 'court-approved contracts,' and thus are 'subject to ordinary rules of contract interpretation under state law.' However, the plan administrator's exercise of discretionary authority in calculating benefits under the terms of the plan would be reviewed for abuse of discretion....[T]he Fourth Circuit ruled that the word 'may' 'authorizes, but does not require, the plan administrator to allocate the cost of the surviving spouse annuity to the alternate payee's portion of the benefit.' ... The Fourth Circuit also noted that this interpretation was consistent with the plan documents." [Gasper v. EIDP, Inc., No. 24-1959 (4th Cir. Dec. 8, 2025)]

Eleventh Circuit Rules Insurer's Interpretation of Preexisting Condition Provision Was Unreasonable

"The court ruled that Reliance's interpretation was unreasonable 'because it completely elides the distinction between receiving medical care for symptoms not inconsistent with a preexisting condition and receiving medical care for a preexisting condition itself.'... The court deemed this position 'unreasonable -- full stop.' ... In the end, the court viewed Reliance as attempting to rewrite its policy after the fact[.]" [Johnson v. Reliance Standard Life Ins. Co., No. 23-13443 (11th Cir. Nov. 21, 2025)]

Statutory Claims in the Eleventh Circuit: The Beginning of the End for Exhaustion?

"The plaintiffs contend that the defendants caused the plan to overpay for the stock by tens of millions of dollars ... [and] sought equitable relief ... [P]laintiffs contended that [1] they had no obligation to exhaust the plan's internal appeals, and [2] assuming such an obligation existed, they should be excused from that requirement.... The Eleventh Circuit began by acknowledging that while '[a]ll circuits require exhaustion in the ERISA context,' the Eleventh Circuit was special. 'Where we diverge is in our application of the exhaustion requirement to statutory violation claims.' " [Bolton v. Inland Fresh Seafood Corp. of Am., Inc., No. 24-10084 (11th Cir. Oct. 15, 2025)]

Seventh Circuit Sticks to the Text in Interpreting ERISA’s Withdrawal Liability Rules

"The Seventh Circuit rejected SuperValu’s contention that the MPPAA required a fund to “deduct contribution units for asset sales qualifying under safe-harbor § 4204 for the full ten-year lookback period.” In fact, the court observed that the MPPAA’s payment-schedule statute does not refer to the safe-harbor statute at all, and thus SuperValu could not smuggle those provisions in to reduce its payments." [SuperValu, Inc. v. United Food & Com. Workers Unions & Emps. Midwest Pension Fund, No. 24-2486 (7th Cir. Oct. 9, 2025)]

District Court Rules Retirees Have Standing to Challenge Bristol-Myers Pension Risk Transfer

"Defendants contended that plaintiffs have not missed a benefit and thus they have suffered no harm from the PRT.... The court further identified a separate basis for Article III standing, which was that the PRT diminished the value of their benefits. This was because 'the Athene transaction ejected Plaintiffs from the ambit of ERISA.' " [Doherty v. Bristol-Myers Squibb Co., No. 24-6628 (S.D.N.Y., Sep. 29, 2025)]

Third Circuit Upholds PBGC Regs and Tells Trucking Company a Deal's a Deal

"The appellate court agreed with the bankruptcy court that the relevant language in MPPAA permitted the two plans to enforce their contract with Yellow and demand liability at the contractually-bargained-for rate, despite that rate being higher than Yellow's actual contributions at the time." [In re Yellow Corp., No. 25-1421 (3d Cir. Sep. 16, 2025)]

Eleventh Circuit Rules That 'Top Hat' Plan Termination Short-Changed Employees

"The court acknowledged that NCR's offering of a lump sum to replace the plan-prescribed annuities was not by itself wrongful.... However, just because NCR could pay a lump sum did not mean that its payments were automatically adequate.... The Eleventh Circuit agreed with the district court that the payments constituted a breach of the plan terms because they 'adversely affect[ed]' the 'accrued benefits' (i.e., the life annuities) of 'any' participant. The word 'any' was key; a lump sum would violate the plan if it 'led to a reduction in the amount of the life annuity of even a single participant.' " [Hoak v. Ledford, No. 24-12148 (11th Cir. Aug. 26, 2025)]

Second Circuit Tightens Standing Rules for Breach of Fiduciary Duty Class Actions

"[T]he Second Circuit agreed with the district court that plaintiffs lacked constitutional and class standing to assert several of their claims because they did not adequately plead that they had suffered individual harm caused by defendants' imprudence or disloyal management.... The Second Circuit also rejected plaintiffs' argument that because they had made allegations supporting a breach of fiduciary duty with respect to some plan processes, the court should conclude that defendants employed a flawed process in general." [Collins v. Northeast Grocery, Inc., No. 24-2339 (2d Cir. Aug. 18, 2025)]

Second Circuit Rules Disability Claimant Didn't Waive Her Right to Sue for Benefits

"[T]he Second Circuit ruled that no reasonable jury 'could conclude that Schuyler actually believed that she was waiving her claim for LTD benefits from Sun Life when she signed the agreement,' and thus she 'didn't knowingly and voluntarily waive her right to pursue her LTD against Sun Life.' The court therefore reversed the judgment below and remanded for further proceedings." [Schuyler v. Sun Life Assurance Co. of Canada, No. 23-498 (2d Cir. Aug. 14, 2025)]

Ninth Circuit Joins Sister Circuits in Applying Effective Vindication Doctrine to Invalidate Health Plan's Arbitration Provision

"[Platt] filed suit against Sodexo, alleging that its imposition of a monthly tobacco surcharge on his employee health insurance premiums violated ERISA.... Sodexo moved to compel arbitration based on a provision that it had unilaterally added to the plan in 2021.... [T]he plan's arbitration provision contained a representative action waiver ... Because this provision precluded Platt from obtaining plan-wide relief explicitly authorized by ERISA, it prevented him from 'effectively vindicating' his rights under ERISA, and thus it was unenforceable." [Platt v. Sodexo, S.A., No. 23-55737 (9th Cir. Aug. 4, 2025)]