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Third Circuit Rules That Claim for Pension Benefits Fails Under Theory of Equitable Estoppel
ERISA Lawyer Blog 
Oct. 17, 2013
"[T]he Third Circuit Court of Appeals noted that ERISA Section 502(a)(3) allows a beneficiary to obtain appropriate equitable relief to redress ERISA violations, and that a beneficiary can make out a claim for appropriate equitable relief based on a theory of equitable estoppel. But to succeed on such theory, the beneficiary must establish: (1) a material misrepresentation, (2) reasonable and detrimental reliance upon the representation, and (3) extraordinary circumstances." [Jenkins v. Union Labor Life Company, No. 12-4310 (3d Cir. Sept. 16, 2013)]
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