In a dispute involving long-term disability (LTD) benefits, a district court in South Dakota held that the Department of Labor's (DOL's) safe harbor for voluntary benefits applied regarding an employee's individual LTD policy. As a result, the LTD policy was not covered by the Employee Retirement Income Security Act of 1974 (ERISA) and the employee's state-law claims (which included bad faith and breach of contract) were not ERISA-preempted.

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