U.S. Court of Appeals for the Eighth Circuit, 2014

The court affirmed summary judgment for MetLife in an ERISA beneficiary dispute. It held that MetLife reasonably determined that the decedent's will did not change the beneficiary and that an unsigned-and-unsubmitted beneficiary form was ineffective because it was not submitted within the plan's thirty-day deadline.

The court held that Jackson plausibly alleged an Establishment Clause violation because the complaint asserted that a state parole stipulation required him to attend a treatment program with religious content to be eligible for early parole, and whether his withdrawal was voluntary or coerced could not be resolved at…