A federal district court in Pennsylvania held that it did not have subject matter jurisdiction to hear a claim for disability benefits under an ERISA plan brought by foreign nationals working in the Republic of Kosovo.  The court explained that absent an “affirmative intention” of Congress that is “clearly expressed” to give a statute extraterritorial reach—which there was not under ERISA—it must presume that ERISA is primarily concerned with “domestic conditions.”  Accordingly, the court determined that it was precluded from hearing plaintiffs’ claims for lack of subject matter jurisdiction.  The case is In re Reliance Standard Life Ins. Co., No. 19-331 (E.D. Pa. June 24, 2019).