In Ajeti v. Life Insurance Company of North America, No. 2:26-cv-03249 (E.D. Pa. Jul. 27, 2026), the United States District Court for the Eastern District of Pennsylvania issued a ruling with broad implications for workers who rely on employer-sponsored disability plans. Notably, the decision reaches even those workers who live and work abroad. The court held that ERISA’s complete preemption doctrine barred seventeen Kosovar employees from pursuing their disability benefits claims in state court. Moreover, the court found that ERISA governs benefit claims arising from U.S.-maintained plans even when the plan participants are foreign nationals who worked overseas. In short, the case is a pointed reminder that where, and under what law, a disability benefits case gets decided can be just as consequential as the merits of the claim itself. If you have a question about your employer-provided disability benefits, consulting with an ERISA disability attorney can help.
The Facts: Seventeen Workers, One U.S. Plan, and a Denied Disability Claim
The seventeen plaintiffs in Ajeti are all citizens of the Republic of Kosovo who worked for AECOM, a U.S.-based global infrastructure firm. Through their employment with AECOM, the plaintiffs participated in an employer-sponsored long-term disability (LTD) plan that AECOM maintained in the United States. When the plaintiffs became disabled and sought LTD benefits, the plan’s insurer — Life Insurance Company of North America (LINA), a subsidiary of New York Life — denied their claims.
The plaintiffs filed suit in state court, asserting claims under state law. LINA and New York Life removed the case to federal court, arguing that ERISA — the Employee Retirement Income Security Act of 1974, 29 U.S.C. § 1001 et seq. — completely preempted the plaintiffs’ state law claims. The plaintiffs moved to remand the case back to state court. The Court denied the motion to remand and, finding that the plaintiffs’ complaint did not state an ERISA cause of action, dismissed the complaint. AJETI v. LIFE INSURANCE COMPANY OF NORTH AMERICA, No. 2:26-cv-03249 (E.D. Pa. Jul 27, 2026)
ERISA Preemption and the Well-Pleaded Complaint Rule: A Primer
To understand why Ajeti matters, you need to understand two intersecting legal concepts: the well-pleaded complaint rule and complete preemption.
Under the well-pleaded complaint rule, federal jurisdiction ordinarily exists only when a federal question appears on the face of a plaintiff’s complaint. A plaintiff can often choose to plead state law claims and stay in state court — even if a federal defense like preemption exists — because a federal defense alone does not justify removal.
Complete preemption is a powerful exception carved out by the Supreme Court. ERISA’s civil enforcement provision, Section 502(a), 29 U.S.C. § 1132(a), has such extraordinary preemptive force that it converts state law claims within its scope into federal claims — regardless of how a plaintiff labels them. When a plaintiff’s state law claim is, at its core, a claim to recover benefits under an ERISA plan, Section 502(a) applies, the well-pleaded complaint rule does not block removal, and federal courts have jurisdiction. The Supreme Court established this framework in Metropolitan Life Insurance Co. v. Taylor, 481 U.S. 58 (1987), and courts have applied it consistently in disability benefits litigation ever since.
In Ajeti, the court found that the plaintiffs’ claims — however styled under state law — were fundamentally claims for disability benefits under an ERISA-governed plan. That determination triggered complete preemption, defeated the motion to remand, and led to dismissal of a complaint that failed to state an ERISA cause of action.
A Significant Holding: ERISA Applies to Foreign Nationals Under U.S.-Maintained Plans
Perhaps the most noteworthy aspect of Ajeti is the court’s analysis of ERISA’s reach beyond U.S. borders. The plaintiffs argued that ERISA should not apply to them because they are foreign nationals living and working in Kosovo. The court rejected that argument.
The Court held that ERISA applies to the benefit claims of foreign nationals when the relevant plan is maintained in the United States and the economic injury — the denial of disability benefits — occurs domestically. The geographic location of plan administration and the financial harm controls the analysis, not the nationality or residence of the plan participant.
This ruling has direct practical consequences. Any multinational employer that administers a single, U.S.-based benefit plan covering workers stationed overseas should understand that those workers are plan participants may be subject to ERISA. And any overseas employee of a U.S. company fighting a disability benefits denial should know that their battle could play out in federal court — under federal law.
The Role of LINA and New York Life
LINA has long operated as one of the most active — and most litigated — disability insurers in the United States. In 2022, New York Life acquired Cigna’s group insurance business, which included LINA, making New York Life one of the dominant carriers in the employer-sponsored group disability market. Millions of American workers — and, as Ajeti confirms, workers employed abroad by U.S. companies — now receive their long-term disability coverage through LINA policies underwritten under the New York Life umbrella.
When LINA denies a disability claim under an ERISA plan, Ajeti confirms that the claimant’s remedy lies exclusively in federal court under ERISA Section 502(a). State law remedies — including state insurance bad faith claims that could yield punitive damages — are off the table. This matters enormously because ERISA’s remedial framework is more restrictive than state law: under ERISA, a claimant’s recovery is typically limited to the wrongfully denied benefits themselves, along with potential attorneys’ fees. The complete preemption doctrine that Ajeti illustrates is one of the primary reasons why experienced, specialized ERISA disability attorney is essential in any disability benefits dispute involving an employer-sponsored plan.
What an ERISA Disability Attorney Wants Claimants to Know
Ajeti carries several practical takeaways for anyone fighting a disability benefits denial under an employer-sponsored plan:
- Your claim will be governed by ERISA, not state law. If your disability coverage comes through your private-sector employer, ERISA almost certainly applies — and complete preemption means you cannot use state court as an end-run around the federal statute.
- The “administrative record” is built before you file suit. ERISA courts typically review benefit denials on the record developed during the insurer’s internal claims and appeals process. The work you do before filing suit — gathering medical evidence, submitting detailed appeals, and creating a complete record — often determines the outcome of your case.
- Deadlines are strict and unforgiving. ERISA imposes rigorous deadlines for administrative appeals and lawsuits. Missing them can permanently bar your claim.
- Foreign nationals employed by U.S. companies are not exempt. Ajeti confirms that the location of the plan, not the nationality of the participant, controls whether ERISA applies.
- Who you hire matters. ERISA practice is a distinct, highly technical area of law. An attorney without specific ERISA experience may miss critical procedural requirements that can sink an otherwise meritorious claim.
The Garner Firm: Your Experienced ERISA Disability Attorney
The attorneys at The Garner Firm, Ltd. have devoted their practice to representing individuals — and in appropriate cases, classes of individuals — whose ERISA disability benefits claims have been wrongfully denied by insurers like LINA and New York Life. We understand how the complete preemption doctrine shapes the litigation landscape, how to build the administrative record that ERISA courts will rely on, and how to develop the legal and factual arguments that give our clients the best chance of recovering the benefits they earned.
Our attorneys handle ERISA disability benefits cases at every stage — from the initial administrative appeal through trial and, where necessary, appeal. We represent clients in individual cases and in complex, multi-plaintiff and class-wide ERISA litigation involving large group insurers and multinational employers.
If you or a loved one has been denied long-term disability benefits under an employer-sponsored plan, do not wait. The deadlines in ERISA cases are strict, and early intervention by an experienced ERISA disability attorney makes a real difference.
Contact The Garner Firm, Ltd. today to schedule a consultation with an experienced ERISA disability attorney. Our Philadelphia office is ready to hear your story.
This blog post is for general informational purposes only and does not constitute legal advice. Reading this post does not create an attorney-client relationship. You should consult a qualified ERISA attorney about your specific situation.