Mealey's (January 8, 2021, 2:07 PM EST) -- FORT LAUDERDALE, Fla. — While a woman may plead both fiduciary duty and benefits claims under the Employee Retirement Income Security Act in a class action alleging an insurer improperly denied coverage for proton beam therapy, they must allege different theories of liability, and any amended action must clearly lay out which allegations apply to which defendant, a federal judge in Florida said Jan. 7....