Employee Benefits & Executive Compensation Blog

The View from Proskauer on Developments in the World of Employee Benefits, Executive Compensation & ERISA Litigation

Category Archives: Equitable Relief

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Yet Another Decision On The Availability of Equitable Surcharge

A district court in Pennsylvania concluded that a decedent’s life insurance plan beneficiaries were entitled to equitable surcharge where the plan administrator failed to, among other things, inform the decedent about the need to convert her group policy to an individual policy. Weaver Brothers Insurance Associates, Inc. v. Braunstein, 2014 WL 2599929 (E.D. Pa. June … Continue Reading

Equitable Surcharge Awarded to Life Insurance Plan Beneficiary

A federal district court in California awarded relief in the form of surcharge to a life insurance plan beneficiary who claimed that a plan administrator failed to provide complete and accurate information in response to inquiries about how to prevent coverage from lapsing. In so ruling, the court stated that the plan administrator’s response to … Continue Reading

Plaintiff’s Claim for Estoppel, Reformation and Surcharge Strikes Out

A divided panel of the Ninth Circuit recently held that plaintiff Gregory Gabriel could not recover, as “appropriate equitable relief,” pension benefits he thought he was owed from the Alaska Electrical Pension Fund, after the Fund stopped paying him pension benefits that it had mistakenly advised him that he was entitled to. In so doing, … Continue Reading

Court Rejects Plaintiff’s Attempt to Prevent Plan from Recouping $250,000 Overpayment

A federal district court in the Northern District of California dismissed an equitable estoppel claim brought by a pension-plan participant seeking to prevent the plan from recouping an overpayment. See Groves v. Kaiser Found. Health Plan, Inc., No. 13-cv-2259, 2014 U.S. Dist. LEXIS 38755 (N.D. Cal. Mar. 24, 2014). Relying on defendants’ representations that participants … Continue Reading

Express Plan Terms Allow Self-Insured Plan to Recover Medical Benefits Paid to Employee Post-McCutchen

In Quest Diagnostics v. Bomani, et al., 11-CV-00951 (D. Conn., June 19, 2013), the court granted Quest Diagnostic’s (“Quest”) motion for summary judgment, ruling that Quest, as the fiduciary to its self-insured medical plan, could recover medical benefits paid to its employee after the employee was injured in an accident and recovered a settlement from … Continue Reading

Sixth Circuit: Plan Fiduciary Reasonably Relied On Benefit Calculations In Communicating To Participant

The Sixth Circuit recently rejected a participant’s claim that a benefit estimate should override the specific benefit promised under the terms of the plan. In Stark v. Mars Inc., No. 12-3956, 2013 WL 1908889 (6th Cir. May 9, 2013) (unpublished), the Sixth Circuit affirmed summary judgment in favor of the plan’s fiduciary committee. The plaintiff, … Continue Reading

U.S. Supreme Court Rules That Plan Terms Trump Equitable Defenses

Today, the U.S. Supreme Court issued its ruling in U.S. Airways, Inc. v. McCutchen in which the Court unanimously ruled that a clearly drafted reimbursement clause will trump all equitable defenses. The Supreme Court’s ruling will likely be viewed favorably by plan sponsors, as it will allow them to anticipate with more certainty the impact … Continue Reading

Second Circuit: Deferential Standard Applies Without Notice To Participants & Reimbursement Claims Are Equitable Relief

Yesterday, the Second Circuit ruled on two important issues of note for ERISA plan sponsors and plan fiduciaries. In Thurber v. Aetna Life Insurance Co., 2013 WL 950704 (2d Cir. Mar. 13, 2013), the Court ruled that participants and beneficiaries are not required to be put on notice that: the plan fiduciary has reserved discretion to … Continue Reading
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