Smith v. Aegon Companies Pension Plan: Enforceability of venue selection clauses
By Nancy G. Ross & Samuel P. Myler
Employee Benefits,
December 2014
While some district courts, such as the Northern District of Illinois in Coleman v. Supervalu, Inc. Short Term Disability Program have agreed with plan participants that venue selection clauses are inconsistent with ERISA, the Sixth Circuit’s recent 2-1 decision in Smith v. Aegon Companies Pension Plan lends strong support for the prevailing view among the district courts that such clauses are enforceable.
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