"[T]he Eighth Circuit, from which this appeal was brought, focused its decision ... on the fact that the plan became overfunded over the course of the litigation at the district court ... [and] concluded that, as a result, the plaintiffs lacked statutory standing under ERISA sections 502(a)(2) and (a)(3). By contrast, the Supreme Court held that the plaintiffs lack constitutional standing, and did not base its decision on the fact that the plan was overfunded." [Thole v. U.S. Bank N.A., No. 17-1712 (S. Ct. Jun. 1, 2020)]  MORE >>