ERISA Post-Distribution Claims and Interpleader

Two questions, not one

When a former spouse is still the named beneficiary of an employer plan governed by ERISA, the dispute usually involves two separate questions:

1. Who must the plan pay? This is decided under ERISA and the plan documents.
2. Can the person who is paid keep the money? This may be decided under state law, for example a waiver in a divorce decree, a breach of contract claim or a request for a constructive trust, if federal law does not preempt it.

Keeping the two questions apart explains most of the cases on this page. A 2026 federal case from Florida, discussed below, shows what happens when both questions arrive in the same interpleader.

The plan-documents rule: Kennedy and Egelhoff

ERISA requires a plan administrator to act “in accordance with the documents and instruments governing the plan.”¹

• In Egelhoff, the Supreme Court held that ERISA preempts a state statute that automatically revokes a former spouse’s designation on divorce, because the statute interfered with paying benefits “simply by identifying the beneficiary specified by the plan documents.”²
• In Kennedy, a former wife had given up her interest in her ex-husband’s savings plan in their divorce decree, but he never changed the designation. The Court held that the waiver was not void under ERISA’s anti-alienation provision, but that the administrator “did its statutory ERISA duty by paying the benefits to [her] in conformity with the plan documents.” It favored a rule of “simple administration, avoid[ing] double liability, and ensur[ing] that beneficiaries get what’s coming quickly.”¹

In a footnote, the Court added: “Nor do we express any view as to whether the Estate could have brought an action in state or federal court against [the former wife] to obtain the benefits after they were distributed.”³ That left open the question this guide calls a post-distribution claim.

Intent is not enough on its own. Some federal courts have applied a federal common-law “substantial compliance” doctrine to ERISA designations. The Fourth Circuit’s version requires that the insured show an intent to change the beneficiary and take “positive action which is for all practical purposes similar to the action required” by the policy.⁴ The Eleventh Circuit has said it has not decided whether that doctrine survives Kennedy, and in an unpublished 2017 decision it affirmed a ruling that an insured who signed change forms but never sent them did not substantially comply.⁵

Community property claims. The plan-documents rule also defeats claims that a spouse owns part of an ERISA benefit under state community property law. In Sun Life v. Estate of Wheeler (W.D. Wash. 2020), an insured’s spouse, as administrator of his estate, claimed group life benefits payable to his mother because community funds had paid the premiums. The estate defaulted, but the court still weighed the claim and held that “ERISA preempts Washington’s community property laws, leaving the Estate without claim to the Proceeds.”⁶ The Texas Supreme Court reached the same result for Texas community property in Barnett v. Barnett (Tex. 2001), holding that although an ERISA life policy bought during the marriage was community property, ERISA preempted the wife’s claims for constructive fraud on the community and a constructive trust over the proceeds paid to the named beneficiary.⁷ In Aetna v. Vacknitz (S.D. Tex. 2019), a Texas widow challenged an online change, made the night before the insured died, that named his former wife. The insurer interpleaded and was discharged, and the claimants settled; no court ruled on the challenge.⁸

Slayer statutes and ERISA

Egelhoff expressly left open whether ERISA also preempts state slayer statutes. The Seventh Circuit has held that ERISA does not preempt them.⁹ The Sixth Circuit, in a published 2024 decision, declined to decide: “we need not definitively resolve the preemption issue left open in Egelhoff because it does not affect the resolution of this case.” It held that ERISA’s pay-the-designated-beneficiary rule “is not absolute,” that the slayer scenario “is more like the doctrines of undue influence and fraud” than the divorce waiver in Kennedy, and that if the Tennessee statute were preempted, “the federal common-law slayer rule controls.” A beneficiary convicted of murdering the participant therefore took nothing under either source of law.¹⁰ See the slayer rule and the decision summary.

No jury for an ERISA interpleader. In Sun Life v. Estate of Jordi (M.D. Tenn. 2020), the insured’s estate invoked Tennessee’s slayer statute against the named beneficiaries and demanded a jury. The magistrate judge struck the demand: “An interpleader action that seeks to determine the rightful beneficiaries to the proceeds of an ERISA plan as among multiple conflicting claimants is an equitable proceeding,” and “[t]he fact that disposition of this case will result in a monetary payout does not change the fundamental nature of the proceeding as one to recover ERISA plan benefits.” Reliance on the slayer statute did not change that either. The claims “sound in equity and there is no right to a jury trial in this case.” The claimants later settled.¹¹

The federal analog: Hillman v. Maretta

Life insurance for federal employees (FEGLI) is governed by a federal statute, not ERISA. Virginia had a law with two parts: one revoked a former spouse’s designation on divorce, and a back-up provision made the former spouse liable to whoever would otherwise have received the proceeds if the first part was preempted. In Hillman, the Supreme Court held that the back-up cause of action was preempted by the federal statute and its regulations. A widow therefore could not recover FEGLI proceeds from the named former spouse after they were paid.¹² The Tenth Circuit later applied Hillman’s reasoning to the Thrift Savings Plan.¹³ See federal programs.

Hillman decided a FEGLI question. It does not by itself decide whether the same result follows under ERISA, which is the question Kennedy left open.

Do post-distribution claims survive under ERISA?

• Third Circuit. In Estate of Kensinger, a former wife had waived her right to her ex-husband’s 401(k) proceeds in their divorce but remained the named beneficiary. The plan had deposited the proceeds with the district court by agreement and been dismissed. The Third Circuit held that the estate “can sue [her] to enforce her waiver and recover the disputed plan proceeds,” and sent the case back to the district court.¹⁴
• Fourth Circuit. In Andochick v. Byrd, the court held “that ERISA does not preempt post-distribution suits against ERISA beneficiaries,” explaining that such suits do not interfere with simple plan administration or expose the plan to double liability, because the plan has no role once it has paid. It noted that it was adopting “the same view as every published appellate opinion to address the question” at that time, citing Kensinger and state appellate decisions from Virginia, Michigan and Oklahoma.¹⁵ In a related interpleader that an insurer filed over a policy on the same decedent’s life, the docket shows the proceeds were deposited with the court in 2012, and a 2016 consent order directed the clerk to pay them to the estate’s co-administrators.¹⁶
• Eleventh Circuit, a timing rule. In MetLife Life & Annuity Co. of Connecticut v. Akpele, the court held that a party who is not a named beneficiary may not sue the plan for benefits, but “may sue a plan beneficiary for those benefits, but only after the plan beneficiary has received the benefits.” The claimant there had tried to enforce a settlement through a motion in the interpleader, while the plan’s trustee was still a party and before the funds were paid out. The court said that claim was not pleaded and not ripe, and that she could sue “in a separate action in which the Plan trustee is not a party,” but only after the benefits were distributed.¹⁷
• Ninth Circuit, a limit. In Carmona v. Carmona, a case about a surviving spouse’s annuity benefits under a pension plan, the court held a state-court constructive trust preempted because it “was explicitly an attempt to avoid ERISA’s QDRO, preemption, and antialienation provisions.” It added that not every state constructive trust, “particularly those that seek to recover ill-gotten gains,” will necessarily be preempted.¹⁸
• New York federal courts. In McCarthy v. Estate of McCarthy, the insurer paid the proceeds into the court registry with all parties’ consent and was dismissed. After a bench trial, the court imposed a constructive trust on the proceeds in favor of the insured’s former wife and children, who were owed coverage under the couple’s divorce settlement, and ordered the clerk to release the funds to them. It held that ERISA did not preempt that “post-distribution constructive trust,” reasoning that the insurer had already paid by depositing the money with the court, had no role in what followed, and faced no risk of double liability.¹⁹
• Texas federal courts. In Flesner v. Flesner, a federal magistrate judge in the Southern District of Texas, sitting with the parties’ consent, said it had not located binding precedent preempting state-law claims to the proceeds of a distributed ERISA plan, and agreed with appellate decisions distinguishing between benefits before and after they are paid.²⁰ Flesner is a trial-court decision and does not bind other courts.
• Pennsylvania federal courts. In Procter & Gamble v. Estate of Rolison, the court first directed the plan administrator to pay the insured’s investment plan accounts to the beneficiary named on his enrollment form, a former girlfriend. It then decided the estate’s crossclaim for a constructive trust in the same case. It held that ERISA did not bar the claim after distribution, but the estate lost on the merits because it could not show by “clear, direct, precise, and convincing evidence” that keeping her as beneficiary was a mistake.²¹
• Tennessee federal courts. ERISA decides whom the plan pays, but once the money is paid, Tennessee law decides whether a constructive trust applies, and federal courts there impose one only on clear and convincing evidence. See ERISA and Tennessee constructive trusts.
• Montana federal court. For an ERISA plan, the District of Montana held Montana’s revocation statute preempted, awarded the benefit to the former spouse named in the plan records, and declined to impose a constructive trust.
• A bankruptcy court in South Carolina. In Beckham v. Barnhardt, a former wife argued that the insurer’s deposit of ERISA life insurance proceeds with the clerk was a distribution, so state law could then decide who kept them. The court disagreed. It saw no South Carolina court treating such a deposit as “a de facto distribution under an ERISA plan,” and ordered the proceeds paid to the named beneficiary. It also confirmed that ERISA does not bar state-law claims against a named beneficiary after distribution, and set those claims for trial in the same proceeding.²²
• Oklahoma federal courts and the Tenth Circuit: claims against the plan versus claims against the people paid. In Hartford Life v. Jones-Atchison, the insurer paid the insured’s supplemental life and accidental death benefits to his parents under the plan’s succession provision, relying on his father’s sworn affidavit that he had no children. Three minor children later intervened through their parents, sued the insurer under state law and ERISA, and crossclaimed against the grandparents. In 2019 the district court held that the claims against the insurer were “directly related to the administration of the Policy and processing of a covered claim,” so ERISA preempted the state-law contract and fiduciary-duty claims. It dismissed the ERISA claim as well, because “[a] plan administrator that pays benefits in accord with established plan procedures when it has ‘no reason to suspect that anything was amiss’ is ‘not obligated to inquire further.’”²³ In 2020 it reached the opposite result on the crossclaims: “crucial to the Court’s prior ruling was the fact that the Children had sued Hartford Life seeking to force the insurance company to take some action in relation to the ERISA policy,” while the crossclaims sought money the grandparents “allegedly received in violation of state law.” ERISA did not preempt them. But the claimants had settled the interpleaded basic life benefit and the interpleader claims had been dismissed. With no diversity jurisdiction, the court declined to keep the state-law crossclaims and dismissed them without prejudice.²⁴ The Tenth Circuit affirmed the dismissal of the ERISA claim; the children did not appeal the state-law rulings.²⁵

The answer can therefore depend on the kind of claim, the kind of benefit, the court and, as Akpele shows, the timing. A suit to enforce a divorce waiver against the paid beneficiary has fared well in the published appellate decisions above. A remedy aimed at redirecting benefits that ERISA itself assigns to someone, such as a surviving spouse’s annuity, or a claim to FEGLI or Thrift Savings Plan money, has not.

Why plans interplead

A plan or insurer that receives competing claims, for example from a named former spouse and from an estate relying on a divorce decree, risks being sued by whichever claimant it does not pay. Interpleader lets it deposit the money with the court and ask to be discharged. See what an interpleader action is and discharge, fees and interest.

Kennedy sounded a note of caution. Responding to the estate’s suggestion that administrators could resolve waiver disputes through interpleader, the Court said that this “merely restates the problem,” because it “would destroy a plan administrator’s ability to look at the plan documents and records conforming to them to get clear distribution instructions, without going into court.”¹ Interpleader does not change the rule that the plan documents decide who the plan pays. In Flesner, the court noted that Kennedy suggested interpleading the proceeds would not discharge the obligation to follow the plan documents, and it applied them.²⁰

Consolidated ERISA post-distribution interpleader

What this guide calls a consolidated ERISA post-distribution interpleader is an interpleader in which, before the court releases the deposited money, it decides both questions: first, who the plan documents say must be paid under Kennedy and Egelhoff; and second, whether a competing claimant’s state-law claim against that payee, such as a divorce waiver, breach of contract or constructive trust claim, means the payee cannot keep the money. The label is this site’s own shorthand. Courts do not use it, and it is not a recognized doctrine. It describes a way of sequencing claims that courts have permitted, not a separate legal rule.

How it works procedurally

• Getting into federal court. Statutory interpleader under 28 U.S.C. § 1335 requires $500 or more at stake, two or more adverse claimants of diverse citizenship, and a deposit or bond. Rule interpleader under Federal Rule of Civil Procedure 22 needs its own basis for federal jurisdiction. See statutory vs. Rule 22 interpleader. In Flesner, the court held that both policies were part of an ERISA plan, and noted that even if one of them were not, it would retain supplemental jurisdiction under 28 U.S.C. § 1367(a) over the claims arising from that policy.²⁰
• Claims between the claimants. Rule 13(g) allows a crossclaim against a coparty “if the claim relates to any property that is the subject matter of the original action.”²⁶ A claimant can use a crossclaim or counterclaim to assert the state-law claim against the named beneficiary in the same case.
• Discharge. Once the stakeholder deposits the funds, it can be dismissed, and the case continues among the claimants. In Flesner, both insurers deposited their policy proceeds and were dismissed before the claimants’ cross-motions for summary judgment were decided.²⁰
• Deciding in order. The court first applies the plan documents, then decides the state-law claim before the money leaves the registry.
• Scheduling: benefits review or ordinary litigation. A suit for ERISA benefits is often put on a case management track built for review of the plan’s administrative record, with limited discovery. A dispute between claimants may not fit that track. In Jones v. MetLife, a claimant’s removed suit that became an interpleader, the court had issued an ERISA case management order requiring “the complete administrative record concerning Plaintiff’s claim for benefits,” then, after at least two parties objected, found that “the objection has merit,” vacated the order and set an ordinary scheduling conference. The order gave no further reasons.²⁷ See when a claimant sues first.
• Decrees that may be QDROs. When a divorce decree required the participant to keep life insurance for a child, claimants sometimes argue the decree is a qualified domestic relations order. Whether that exception reaches welfare-plan life insurance is not settled everywhere, and in MetLife v. Evans the claimants settled before the court decided it. See decrees that require insurance for a child.

Flesner v. Flesner as an example

After a couple divorced in Texas, the husband died without changing the former wife’s designation under two employer-provided life insurance policies. The divorce decree divested her of rights in benefits existing by reason of his employment. She sued the insurers and the executor of his estate. The executor and another claimant sued her in state court for breach of contract, and that case was removed and consolidated. The insurers deposited the proceeds and were dismissed.²⁰

The court held that ERISA governed both policies and that, under Kennedy, the plan documents made the former wife the beneficiary, so the proceeds “should thus be disbursed to Plaintiff.” It then said: “Once disbursed in accordance with the plan documents, however, the proceeds may be the subject of non-ERISA claims,” and that because the breach of contract claim was already before it, it would “resolve it here rather than pay the proceeds to Plaintiff and require Defendants to refile their claims in state court.” It held the claim not preempted and granted summary judgment to the executor and the other claimant on breach of the divorce decree, but denied their request for attorney’s fees because their evidence did not prove presentment of the claim, which Texas law requires.²⁰ See the summary in the decisions library.

United of Omaha v. Black: the timing question

A 2026 order from the Northern District of Florida shows both the approach and its main obstacle. After the insured died, the insurer received competing claims to life insurance proceeds under a policy governed by ERISA. It interpleaded the proceeds, leaving the two claimants to litigate: the insured’s former girlfriend, who was the sole beneficiary named on his enrollment form, and his mother, who crossclaimed against her. The mother alleged that the designation was invalid (incomplete, forged, the product of undue influence, or contrary to what the insured later told family members) and, in the alternative, asked for a constructive trust in favor of the insured’s estate.²⁸

On the named beneficiary’s motion for judgment on the pleadings, the court held that the mother had not alleged facts supporting any of her challenges to the designation, so “[u]nder the policy, which is governed by ERISA, the funds are properly” the named beneficiary’s, and that determination “resolves this interpleader action.” The court read the constructive trust count as a claim for unjust enrichment, and said that claim was different: citing Kennedy and Akpele, it said “post-distribution challenges present different questions—namely, whether state-law rules warrant divesting a beneficiary of distributed proceeds.”²⁸

The court was unsure such a claim belonged in the interpleader before distribution. It said the proper outcome “appears” to be an order dismissing the challenges to the designation on the merits, directing the clerk to pay the funds to the named beneficiary, and dismissing the unjust enrichment claim “without prejudice to a new unjust-enrichment action” under state law. Before deciding, it invited the parties to file optional briefs on “whether an unjust enrichment action against [her] is appropriate before distribution in light of Akpele and Kennedy’s directive.”²⁸ The named beneficiary’s supplemental brief urged the court to keep the claim and decide it in the same case (ECF No. 46). This site has not located a public record of any later ruling on that question.

Black is the clearest illustration on this page of what is at stake. In the Eleventh Circuit, Akpele’s statement that a post-distribution suit may be brought “only after” the beneficiary receives the benefits gives a court reason to pay the named beneficiary first and leave the state-law claim to a new lawsuit, which is the second suit this approach tries to avoid.

When the plan has already paid

The examples above involve money still held by the plan or the court. When the money has already gone out, the same logic can run in reverse. In Wilty v. Prudential, an ERISA case in Tennessee, the insurer had paid the death benefit to the insured’s widow before other claimants sued. It counterclaimed for interpleader, and the court granted a temporary restraining order freezing the funds paid to her, finding the insurer likely to succeed on a constructive trust claim because she had not been ruled out as a suspect in the death. A consent order then required her to return part of the money and froze the rest for deposit in the registry. The case later settled, so no court decided the slayer question. See When a claimant sues first.²⁹

A plan can also recover a payment made in error. In Transocean U.S. Savings Plan v. Thure, a plan that had paid the same benefit twice, first to the insured’s estate and then to her former husband as the named beneficiary, obtained an equitable lien on the funds still held by the estate. The court added that any state-law claim by the estate against the former husband was “a contract or state-law dispute” separate from the ERISA case.³⁰

Why it can save a second lawsuit

Without consolidation, the plan or the court pays the named beneficiary, and the other claimant must then file a new suit, often in state court, to recover the money from that person, who may already have spent it. Deciding both questions while the fund is still in the registry avoids a second case, a second round of service and discovery, and the risk that the money is gone by the time a second judgment is entered. Flesner gave this reason for deciding the contract claim itself.²⁰

Limits

• It depends on the court’s view of preemption. In a court that holds the post-distribution claim preempted, as courts have for FEGLI and the Thrift Savings Plan and as the Ninth Circuit did for a constructive trust designed to get around ERISA, the second question ends in the named beneficiary’s favor.¹²¹³¹⁸
• Timing rules can stand in the way. In the Eleventh Circuit, Akpele says a post-distribution suit may be brought only after the beneficiary has received the benefits, in a separate action without the plan’s trustee as a party. Black shows a district court in that circuit treating that as a reason to question deciding the claim before distribution. McCarthy and Flesner reached the merits while the funds were still in the registry, but they are trial-court decisions outside the Eleventh Circuit. A bankruptcy court in South Carolina refused to treat a deposit as a distribution, and in a Tenth Circuit case the district court declined to keep the state-law claims once the federal interpleader claims were gone.^1728192225
• It does not change who the plan pays. The plan-documents rule still decides the first question, and Kennedy rejected interpleader as a way for administrators to resolve waiver disputes instead of following the plan documents.¹
• It needs an interpleader and a pleaded claim. A plan that pays the named beneficiary without interpleading leaves no fund in court to hold back. A claimant who does not plead the state-law claim in the interpleader may have to bring it separately.
• Not every employer policy dispute raises these questions. In Minnesota Life v. Roberson, a dispute over an employer group life policy, the court applied Washington law and held that the state’s revocation statute did not reach a former partner the insured never married or registered with. The order did not discuss ERISA or Egelhoff, and it did not involve a post-distribution claim.³¹ See Divorce and beneficiary designations.
• State law supplies the claim, and its rules apply. In Flesner, the claimants won on breach of contract but lost their fee claim for lack of proof of presentment under Texas law.²⁰
• Pension benefits raise extra issues. Kennedy involved a pension plan and its anti-alienation rule, and Carmona involved surviving-spouse annuity rights that ERISA itself protects. Life insurance under a welfare plan, as in Flesner, does not raise those particular issues.

Related guides

• When a claimant sues first
• Divorce and beneficiary designations
• Federal programs
• Retirement accounts
• Statutory vs. Rule 22 interpleader
• Key decisions
• Undue influence and capacity
• Glossary

Footnotes

1. Kennedy v. Plan Administrator for DuPont Savings & Investment Plan, 555 U.S. 285 (2009). Justia. ↩ ↩² ↩³ ↩⁴

2. Egelhoff v. Egelhoff, 532 U.S. 141 (2001), as quoted in Kennedy, 555 U.S. 285. ↩

3. Kennedy, 555 U.S. 285, n.10. ↩

4. Phoenix Mutual Life Ins. Co. v. Adams, 30 F.3d 554 (4th Cir. 1994). Caselaw Access Project. ↩

5. Metropolitan Life Ins. Co. v. Waddell, 697 F. App’x 989 (11th Cir. 2017) (unpublished), including n.5. govinfo (PDF). ↩

6. Sun Life Assurance Co. of Canada v. Estate of Wheeler, No. 2:19-cv-00364-JLR (W.D. Wash.), order granting interpleader and default judgment, ECF No. 31 (Jan. 28, 2020), at 6, 9–10, 12, court order (PDF); order granting interpleader disbursement, ECF No. 33 (Apr. 17, 2020); judgment, ECF No. 34 (May 11, 2020), court judgment (PDF); clerk’s order of default, ECF No. 17 (June 26, 2019). ↩

7. Barnett v. Barnett, 67 S.W.3d 107 (Tex. 2001). FindLaw (unofficial copy). ↩

8. Aetna Life Ins. Co. v. Vacknitz, No. 4:19-cv-01590 (S.D. Tex.): order granting interpleader and discharge, ECF No. 13 (Oct. 10, 2019); order of dismissal on announcement of settlement, ECF No. 17 (Oct. 29, 2019); final judgment, ECF No. 19 (Nov. 20, 2019), court judgment (PDF). The description of the claims comes from the case file, not from a ruling; no court decided capacity. ↩

9. Laborers’ Pension Fund v. Miscevic, 880 F.3d 927, 934 (7th Cir. 2018), as described in Standard Ins. Co. v. Guy, 115 F.4th 518 (6th Cir. 2024), slip op. at 5. ↩

10. Standard Ins. Co. v. Guy, 115 F.4th 518 (6th Cir. 2024), slip op. at 5, 9, 12, court copy (PDF); Sixth Circuit (PDF). ↩

11. Sun Life Assurance Co. of Canada v. Estate of Jordi, No. 2:18-cv-00055 (M.D. Tenn.), memorandum order striking jury demand, ECF No. 59 (Aug. 5, 2020), at 3 n.2, 4, 6 (cited by docket number); final judgment, ECF No. 68 (Oct. 16, 2020), court judgment (PDF). The insurer was dismissed by ECF No. 39 (Oct. 1, 2018); the case was stayed by ECF No. 42 (Oct. 15, 2018) and the stay lifted by ECF No. 47 (May 13, 2020). ↩

12. Hillman v. Maretta, 569 U.S. 483 (2013). Cornell LII. ↩ ↩²

13. Evans v. Diamond, 957 F.3d 1098 (10th Cir. 2020). ↩ ↩²

14. Estate of Kensinger v. URL Pharma, Inc., 674 F.3d 131 (3d Cir. 2012). Caselaw Access Project. ↩

15. Andochick v. Byrd, 709 F.3d 296 (4th Cir. 2013). Caselaw Access Project. ↩

16. Principal Life Ins. Co. v. Andochick, No. 1:12-cv-00536 (E.D. Va.), docket entries for Aug. 2, 2012 (ECF No. 16) and Mar. 22 and Apr. 8, 2016 (ECF Nos. 25, 26). CourtListener docket (unofficial). The orders themselves were not available in a public copy; this summary relies on the docket text. ↩

17. MetLife Life & Annuity Co. of Connecticut v. Akpele, 886 F.3d 998 (11th Cir. 2018). U.S. Court of Appeals for the Eleventh Circuit (PDF). ↩ ↩²

18. Carmona v. Carmona, 603 F.3d 1041 (9th Cir. 2010). Caselaw Access Project. ↩ ↩²

19. McCarthy v. Estate of McCarthy, 145 F. Supp. 3d 278 (S.D.N.Y. 2015) (Furman, J.). Caselaw Access Project. ↩ ↩²

20. Flesner v. Flesner, 845 F. Supp. 2d 791 (S.D. Tex. 2012) (Johnson, M.J.). HallApproved (unofficial copy, from CourtListener data). ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸

21. Procter & Gamble U.S. Business Services Co. v. Estate of Rolison, No. 3:17-cv-00762 (M.D. Pa. Apr. 29, 2024), ECF No. 222. govinfo (PDF). ↩

22. Beckham v. Barnhardt (In re Barnhardt), Adv. No. 17-80038-jw (Bankr. D.S.C. Jan. 10, 2018) (supplemental order), ECF No. 93; see also order of Nov. 21, 2017, ECF No. 81. govinfo (PDF, Jan. 10, 2018); govinfo (PDF, Nov. 21, 2017). ↩ ↩²

23. Hartford Life & Accident Ins. Co. v. Jones-Atchison, No. 5:17-cv-00654 (W.D. Okla.), order, ECF No. 79 (Aug. 23, 2019), at 9–12, court order (PDF). ↩

24. Hartford Life & Accident Ins. Co. v. Jones-Atchison, No. 5:17-cv-00654 (W.D. Okla.), order, ECF No. 125 (Aug. 12, 2020), at 5–7, court order (PDF); judgment, ECF No. 126 (Aug. 12, 2020), court judgment (PDF). ↩

25. Hartford Life & Accident Ins. Co. v. Jones-Atchison, No. 20-6135 (10th Cir. Sept. 20, 2021) (unpublished). govinfo (PDF). ↩ ↩²

26. Fed. R. Civ. P. 13(g). Cornell LII. ↩

27. Jones v. Metropolitan Life Ins. Co., No. 2:24-cv-01967 (E.D. La.), ERISA case management order, ECF No. 26 (Dec. 3, 2024); order, ECF No. 29 (Dec. 13, 2024). ↩

28. Order regarding motion for judgment on the pleadings, United of Omaha Life Ins. Co. v. Black, No. 4:25-cv-168-AW-MAF (N.D. Fla. Jan. 23, 2026), ECF No. 44. Court order (PDF). ↩ ↩² ↩³ ↩⁴

29. Wilty v. Prudential Ins. Co. of America, No. 2:18-cv-02602-JTF (W.D. Tenn.), ECF No. 29 (Sept. 25, 2018), court order (PDF); ECF No. 41 (Nov. 7, 2018). ↩

30. Transocean U.S. Savings Plan v. Thure, No. 4:21-cv-03969 (S.D. Tex. July 5, 2022). govinfo (PDF). ↩

31. Minnesota Life Ins. Co. v. Roberson, No. 2:18-cv-01058-RAJ (W.D. Wash. Aug. 2, 2019), ECF No. 31. Court order (PDF). ↩