Two recent 9th U.S. Circuit Court of Appeals decisions address Social Security offsets under disability income plans subject to the Employee Retirement Income Security Act. The first case, Bilyeu v. Morgan Stanley Long Term Disability Plan, 2012 DJDAR 8328 (9th Cir. June 20, 2012), may provide relief to some participants. The second case, Renfro v. Funky Door Long Term Disability Plan and The ServiceMaster Long Term Disability Plan...
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