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Second Circuit: Class-Wide Reformation Is Appropriate Equitable Relief
Proskauer's ERISA Practice Center Dec. 29, 2014 "[T]he Court rejected CIGNA's contention that class-wide reformation was inappropriate because the challenged communications were made by the plan administrator, rather than the plan sponsor.... The Court held that on the basis of generalized evidence, including the company-wide communications of an 'equal value' benefit and the evidence indicating that the vast majority of plan participants read and relied on these communications, the Court could infer that the entire class of participants had been misled by CIGNA and thus misunderstood the plan terms and their effect." [Amara v. CIGNA, Nos. 13-447-cv and 13-526 (2d Cir. Dec. 23, 2014)] |
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