Church Plan Case Cut Short Too Soon, 7th Circ. Says

Law360 (August 13, 2019, 9:22 PM EDT) -- The Seventh Circuit on Tuesday held that a lower court granted summary judgment too early in a suit accusing OSF HealthCare System of misusing the Employee Retirement Income Security Act's church exemption, saying the judge didn’t allow enough time for pertinent discovery.

The district court took an “unduly narrow” view of the facts of the case when it granted OSF’s motion months before discovery was to close in the case and denied postponement, the panel said. The court’s explanation that the employees failed to diligently conduct the needed discovery overlooked delays imposed by both the court and OSF, as well as...

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