Mealey's ( October 10, 2023, 9:16 AM EDT) -- PASADENA, Calif. — In an unpublished memorandum disposition rejecting the appellant’s reliance on Bristol SL Holdings, Inc. v. Cigna Health & Life Ins. Co., a Ninth Circuit U.S. Court of Appeals panel ruled in part that a debt collector “lacks derivative authority to bring [Employee Retirement Income Security Act] claims as a second assignee.”...