Mogel v. UNUM Life Insurance, No. 08-1334. This is an ERISA case. It holds that “security accounts” that were established to fund death benefits are not separate accounts and therefore UNUM’s ERISA-based fiduciary duty applies. UNUM claims that it complied with its fiduciary duties by “delivering a checkbook” (with small limits on the amount of the checks that could be written). This seems pretty obvious, but it is a reversal of the District Court.