(January 27, 2022, 4:27 PM EST) -- TACOMA, Wash. — A disability claimant’s state law claims for breach of contract, breach of the duty of good faith, negligent claims handling and violations of Washington law can proceed because the individual disability income policy at issue is not a plan governed by the Employee Retirement Income Security Act, a Washington federal judge said Jan. 19 in rejecting the insurer’s argument that the state law claims are preempted by ERISA....