The Friday Five: Five ERISA Litigation Highlights - May 2026

Why It Matters

These decisions clarify how courts balance contractual choice, accurate benefit offsets, and evidentiary standards, shaping risk and compliance for multi‑state disability plans.

Key Takeaways

• California court upheld Massachusetts choice‑of‑law in 1972 LTD policy.
• Administrator reclaimed $16,000 overpayment after misapplying Social Security offsets.
• Summary judgment denied where credible physicians’ opinions on COVID‑19 disability conflicted.
• Late 66‑day appeal decision triggered de novo review and plaintiff’s summary judgment win.
• Court affirmed termination of LTD benefits when symptoms lacked physical‑condition link.

Pulse Analysis

The Moorhead ruling underscores that federal courts will honor a contract’s choice‑of‑law provision when it was reasonable at the time of execution. By applying Massachusetts law to a policy drafted in 1972, the Northern District of California signaled that older ERISA contracts can escape newer state consumer‑protection statutes. Plan sponsors with nationwide workforces must therefore review legacy policies for embedded choice clauses and assess whether they remain defensible under current federal standards, especially as states continue to expand insurance consumer safeguards.

Harling’s decision highlights the financial stakes of accurate offset calculations. An administrative error that ignored a claimant’s disabled widow’s benefits led to a $16,000 overpayment, which the court affirmed the insurer could recover. The case illustrates that plan administrators must maintain rigorous data‑integration processes between ERISA plans and external benefit programs such as Social Security. Misreporting not only inflates costs but also opens the door to litigation, prompting insurers to invest in better reporting systems and clearer claimant communication to avoid costly reimbursements.

The remaining three cases collectively refine evidentiary thresholds in LTD disputes. The Delvalle court reiterated that conflicting credible medical opinions preclude summary judgment, preserving the jury’s role in credibility assessments. Booth’s de novo review of a delayed appeal decision affirmed that procedural timeliness directly affects substantive outcomes, while King demonstrated that benefits can be lawfully terminated when symptom causation cannot be medically linked to a physical condition. Together, these rulings urge plan administrators to tighten claim‑review timelines, document medical causation meticulously, and prepare for robust fact‑finding at trial, thereby reducing exposure to adverse judgments.