Mealey's (August 15, 2019, 12:44 PM EDT) -- CHICAGO — A federal judge in Illinois abused her discretion in denying a motion to postpone a summary judgment decision on whether the Employee Retirement Income Security Act’s church plan exemption is applicable to two defined-benefit plans offered by a nonprofit health care corporation, the Seventh Circuit U.S. Court of Appeals ruled Aug. 13 (Sheilar Smith, et al. v. OSF Healthcare System, et al., No. 18-3325, 7th Cir., 2019 U.S. App. LEXIS 24065)....