Mealey's (October 6, 2016, 3:19 PM EDT) -- NEW ORLEANS — A Fifth Circuit U.S. Court of Appeals panel on Sept. 15 said that its previous conclusion that a plaintiff’s bare allegation on the purported statutory right to “proper plan management” under the Employee Retirement Income Security Act is insufficient to meet the injury-in-fact prong of Article III standing remains as valid after the U.S. Supreme Court’s ruling in Spokeo Inc. v. Robins (136 S. Ct. 1540, 194 L. Ed. 2d 635 [2016]), as it was before Spokeo was decided (William Lee, et al. v. Verizon Communications Inc., et al., No. 14-10554, 5th Cir.; 2016 U.S. App. LEXIS 16929)....