NEW YORK - The Second Circuit U.S. Court of Appeals on June 10 found that a commercial general liability insurer has a duty to defend its insured against underlying Employee Retirement Income Security Act claims, vacating and remanding for the lower court to determine whether the insurer also has a duty to indemnify (Euchner-USA, INC., et al. v. Hartford Casualty Insurance Co., No. 13-2021-cv, 2nd Cir.; 2014 U.S. App. LEXIS 10797).