Foster v. Sedgwick Claims Management Services, Inc.

EDWARDS, Senior Circuit Judge:

This appeal raises, two issues regarding the reach and application of the Employee Retirement Income Security Act of. 1974 (“ERISA”), 29 U.S.C. § 1001 et seq., with respect to private benefit plans. The first issue concerns the definition of “payroll practices” that are exempt from ERISA. The second addresses whether terms of the ERISA plan at issue in this case grant discretion to the plan administrator sufficient to warrant deferential review of the administrator’s benefit determinations.

In July 2014, Appellant, Kelly Foster, sued Sedgwick Claims Management…