"Unlike several of its sister appellate courts, the US Court of Appeals for the First Circuit has never held that promissory or equitable estoppel is a form of relief available under Section 502(a)(3) of ERISA. Each time the issue has confronted it, the court has ruled that the plaintiff failed to allege the elements necessary for an estoppel claim, rendering it unnecessary to decide whether such a claim might in fact be cognizable.... In its latest encounter with the issue, the First Circuit continued on the same path, rejecting a pension plan participant's claim for benefits that allegedly had been promised to him but that were not provided under the terms of the plan." [Guerra-Delgado v. Popular, Inc., No. 13-2065 (1st Cir. Dec. 18, 2014)]