(June 9, 2016, 3:11 PM EDT) -- YAKIMA, Wash. — Because a disability claimant did not allege any “systemic breaches” of fiduciary obligations by a disability insurer or administrator, a breach of fiduciary claim alleged under the Employee Retirement Income Security Act against the defendants must be dismissed, a Washington federal judge said May 31 (Timothy Dahmen v. Liberty Mutual Group Inc., et al., No. 15-76, E.D. Wash.; 2016 U.S. Dist. LEXIS 70912)....