Class Dismissed — Pipefitters Steamed

Law360, New York (September 15, 2011, 4:00 PM EDT) -- On Aug. 12, 2011, the Sixth Circuit released its decision in Pipefitters Local 636 Insurance Fund, et al. v. Blue Cross Blue Shield of Michigan, ___ F.3d ___, 2011 (6th Cir. Aug. 12, 2011) (Pipefitters). On an interlocutory appeal, the court reversed an order certifying a class of hundreds of multi-employer trust funds asserting fiduciary claims arising under the Employee Retirement Income Security Act.

As discussed below, the decision is significant (1) for its application of the “rigorous analysis” standard and its directive that courts analyze...
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