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In Unpublished Opinion, Fourth Circuit Reminds Us Who Can Sue Under ERISA
ERISA Lawyer Blog 
[Guidance Overview] Aug. 7, 2011
In this case, the district court based its ruling on its findings that:[the individual plaintiff] lacked standing to sue the Clark Group under ERISA, because she failed to show an injury in fact .... ISN lacked jurisdiction to sue under section 502(a)(2) of ERISA, as it was Plan sponsor -- not a fiduciary of the Plan.
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