A Minnesota court dismissed the Williams v. Target tobacco surcharge case.
On July 22, 2026, a Minnesota federal court dismissed claims that a tobacco surcharge violated ERISA nondiscrimination rules.
What the court decided.
July 22, 2026
The District of Minnesota dismissed the claims, No. 24-CV-3748.
No Standing on Self-Dealing
The court found no standing on the self-dealing claim.
No Notice Required
It held that ERISA does not require a physician-accommodation notice.
Practical effects.
Still Offer an Alternative
Wellness rules still require a reasonable alternative standard.
Check Notices
Plan materials should describe the alternative clearly.
Rulings Differ
Other courts may decide these claims differently.
Review With Counsel
Have counsel look at the surcharge design.
Quick answers.
Short answers. This is general information, not legal or tax advice.
Can we keep a tobacco surcharge?
Many plans do, within the wellness program rules.
Does the ruling bind other courts?
No. It is one district court.
Where is more information?
See the sources below.
Where the rules and figures come from.
Each figure on this page comes from the source below. Amounts are indexed or updated over time, so confirm current figures before relying on them.
Holland & Knight on Tobacco Surcharge Rulings
Williams v. Target and Spencer v. Campbell Soup, July 22, 2026.
KFF on Kennedy v. Braidwood
The Supreme Court upheld ACA preventive services, with open questions.
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