Mealey's (July 28, 2020, 3:08 PM EDT) -- TAMPA, Fla. — A Florida federal judge on July 24 dismissed a disability claimant's breach of fiduciary allegation against his former employer and disability insurer after determining that the claimant failed to prove that the defendants had a duty to routinely evaluate the disability plan at issue (Lee Fogle v. IBM Corp., et al., No. 19-2896, M.D. Fla., 2020 U.S. Dist. LEXIS 130791)....