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The LHD/ERISA Advisor: ERISA Exhaustion Requirement Not Satisfied by Verbal Appeal When Plan Required Written Appeal

In Ligotti v. United Healthcare Services, 2021 U.S. Dist. LEXIS 106992 (S.D. Fla., June 8, 2021), a Florida district court held that a health care provider challenging claim denials on behalf of his patients cannot satisfy...more

The LHD/ERISA Advisor - October 2020

As we enter the final months of 2020, this is a time to reflect on a year of unprecedented challenges. Although Covid-19 changed our lives in many ways, it did not halt new legal developments in the life, health and...more

The LHD/ERISA Advisor - October 2020: Utah Court Rules ERISA Plan Was Wrong to Deny Coverage for Mental Health Care Received at...

In Raymond M. v. Beacon Health Options, Inc., 2020 U.S. Dist. LEXIS 94615 (D. Utah, May 29, 2020), a Utah district court held that an ERISA plan improperly applied acute-level criteria when denying benefits for a...more

The LHD/ERISA Advisor - October 2020: Tenth Circuit Finds District Court Applied Wrong Standard of Review in Evaluating Plan...

In Lyn M. v. Premera Blue Cross, 2020 U.S. App. LEXIS 23395 (10th Cir. July 24, 2020), the Tenth Circuit held that a district court had applied the wrong standard of review and incorrectly evaluated an ERISA plan...more

The LHD/ERISA Advisor: Ninth Circuit Reverses Award of Attorneys' Fees

In Gorbacheva v. Abbott Laboratories Extended Disability Plan, et al., 29 U.S. App. LEXIS 36542 (N.D. Cal. Dec. 10, 2019), the Ninth Circuit reversed a district court's award of attorneys' fees to an ERISA claimant as...more

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