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Fourth Circuit Holds ERISA § 502(a)(2) Claims in Defined Contribution Plans Are Individualized and Cannot Be Certified as Mandatory Classes
Roberts Disability Law 
Mar. 11, 2026 "the Fourth Circuit reversed a district court's class certification order in an ERISA fiduciary-breach lawsuit involving a defined contribution retirement plan. The court held that claims brought under ERISA Section 502(a)(2) seeking recovery for investment losses in participants' individual accounts constitute individualized monetary claims and therefore cannot be certified as mandatory classes under Federal Rule of Civil Procedure 23(b)(1)." [Trauernicht v. Genworth Fin. Inc., No. 24-1880 (4th Cir. Mar. 10, 2026)] MORE >> |
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