Slim v. Life Insurance Company of North America, et al. — 1st Cir. (Nov 4, 2026)
The First Circuit takes up Slim, a dispute over life insurance arranged through his employer, Royal Blue Hospitality. Slim says he selected extra coverage for his wife and paid premiums through payroll deductions. After her death, he sought the additional insurance payment, but the insurer said the required proof of insurability and written approval were missing. Those are requirements for putting the extra coverage into effect, not simply for collecting premiums. His lawsuit involves both the insurer, Life Insurance Company of North America, and his employer. But this argument concerns more than whether benefits were payable under the policy. Slim also alleges a breach of fiduciary duty in the handling of his coverage. The district court rejected that route to relief, and he wants it reconsidered. The governing law is ERISA, the federal employee-benefits statute. One provision allows a beneficiary to enforce benefits due under the plan; another authorizes other appropriate equitable relief for violations. You will hear the lawyers refer to these routes as a-one-b and a-three. The distinction matters if a claim for the promised insurance payment fails, but a separate wrong in administering the plan might still need a remedy. Slim will argue that the district court shut off that second route too early, and that an equitable award could reflect the value of lost benefits. The response will be that a request to pay plan benefits cannot become a separate equitable claim merely by calling it a fiduciary breach. The judges will focus closely on the complaint and its prayer for relief: the part specifying what the court is asked to order. Keep two questions separate: what remedies the law permits, and whether this particular complaint actually requested one of them. Questions about a possible monetary award are not findings that anyone is liable or that Slim is already entitled to that award.
Slim v. Life Insurance Company of North America, et al. (No. 25-1570) — U.S. Court of Appeals for the First Circuit, argued November 4, 2026.
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