"[T]he Eighth Circuit joined a number of other circuits in recognizing equitable remedies of reformation and surcharge based on a breach of fiduciary duty under ERISA. The claim for supplemental life insurance benefits under the employer's group policy was denied because the employee failed to submit evidence of insurability as required under the plan. However, in concluding that the plan insurer breached its fiduciary duties, the court relied primarily on the actions and omissions of the employer.... [T]he court seemed to hold MetLife responsible for the employer's failure to provide a summary plan description.... [It] was also the employer's responsibility to properly enroll individuals. If the employer did so improperly, this should not be a basis for imposing liability on MetLife." [Silva v. Metropolitan Life Ins., No. 13-2233 (8th Cir. Aug. 7, 2014)]