February Roundup: A Botched Beneficiary Change, and a Discrimination Claim That Didn't Make It Past the Pleadings

Hosts Kian Hudson and Mark Crandley examine two recent Seventh Circuit decisions that clarify critical pleading and compliance standards.

Cases Discussed:

Packing Corporation of America Thrift Plan v. Dina Langdon

When a divorced employee sends a fax requesting a beneficiary change but dies before submitting the proper forms, who gets the retirement benefits—the ex-wife or the estate? The court addresses whether the "substantial compliance" doctrine survives recent Supreme Court precedent and draws a bright line: good intentions aren't enough if you don't follow the plan's procedures.

Miao v. United Airlines

After being removed from a flight following a dispute over overhead bin space, a passenger alleges racial discrimination. The court tackles a fundamental question: when is differential treatment enough to get past a motion to dismiss? The answer reveals the high bar discrimination plaintiffs face at the pleading stage, even when they identify a comparator.