under the plan.” 29 U.S.C. § 1140. To establish a claim for a violation of § 510, Fitzgerald must show Action “had a specific intent to interfere with [his insurance] benefits, but that may be shown by circumstantial evidence.” Register v. Honeywell Fed. Mfg. & Techs., LLC, 397 F.3d 1130, 1136-37 (8th Cir.2005) (citing Regel v. K-Mart Corp., 190 F.3d 876, 881 (8th Cir.1999)). In the absence of direct evidence of an employer’s deliberate interference with future benefits, we analyze § 510 interference claims using the McDonnell Douglas three-part burden-shifting analysis common to Title VII and ADEA cases. See Texas Dep’t of Cmty. Affairs v. Burdine, 450 U.S. 248, 101 S.Ct. 1089, 67 L.Ed.2d 207 (1981); Libel v. Adventure Lands of America, Inc., 482 F.3d 1028, 1035 n. 7 (8th Cir.2007) (<HOLDING>). Initially, Fitzgerald must make a prima facie
holding that without a link to the challenged decision stray remarks did not constitute indirect evidence of discrimination sufficient to satisfy the final prong of the mcdonnell douglas framework holding because the plaintiffs erisa claim is based on alleged circumstantial evidence  the eighth circuit analyzed the claim under the mcdonnell douglas framework recognizing that the mcdonnell douglas framework is less useful in the context of an alleged discriminatory disciplinary decision than in the context of an alleged discriminatory hiring decision holding because libels erisa claim is based on alleged circumstantial evidence  we analyze it under the mcdonnell douglas framework holding that a patternorpractice claim is not available to individual plaintiffs although patternorpractice evidence may be relevant to proving an otherwiseviable individual claim for disparate treatment under the mcdonnell douglas framework