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Fourth Circuit Takes Expansive View of Equitable Relief for Plan Participants Against Fiduciaries
Wombyle Carlyle Link to more items from this source
July 9, 2012
"Courts have traditionally interpreted ERISA Section 502(a)(3) as providing a very narrow opportunity for recovery, because the recovery had to be equitable, not legal, in nature; thus, claims for compensatory damages typically have not been not available. In Amara, the Supreme Court opened the door to a more expansive interpretation of 'equitable relief,' specifically including surcharge and equitable estoppel as possible remedies available under ERISA Section 502(a)(3). [In this case over an insurance company's denial of benefits for an ineligible dependent mistakenly enrolled in an employer's life insurance plan, the participant] argued that the equitable remedies of surcharge as well as equitable estoppel should be available ... to allow monetary compensation caused by MetLife's fiduciary breach. The Fourth Circuit Court of Appeals agreed[.]" [McCravy v. Metropolitan Life Ins. Co., 2012 U.S. App. Lexis 13683 (4th Cir. Jul. 5, 2012)]

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