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Plan Terms and Tax Rules: What Does “Retire” Mean To Qualify for Retirement Benefits?

In Metzgar v. U.A. Plumbers & Steamfitters Local No. 22 Pension Fund, 2022 U.S. App. LEXIS 5466 (2d Cir. Mar. 2, 2022), the Second Circuit in a summary order affirmed the district court’s decision granting summary judgment in...more

District Court Rejects Reasonableness Requirement for “Actuarial Equivalence” Used to Calculate Alternative Annuities

On March 4, 2022, the District Court for the District of Massachusetts dismissed, pursuant to Fed. R. Civ. P. 56, ERISA claims brought by a former employee who retired early at the age of 62 and receives retirement benefits...more

Eighth Circuit: District Court Improperly Resolved Factual Disputes on Summary Judgment in ERISA Benefits Case, But Error Harmless

In Avenoso v. Reliance Standard Life Insurance Company, No. 21-1772, 2021 U.S. App. LEXIS 35264 (8th Cir. Nov. 30, 2021), the Eighth Circuit clarified its position in a circuit split over the proper judicial procedure for...more

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