The Second Circuit determined that a district court erred when it denied an attorney fee award to an ERISA plaintiff who had sought benefits from a plan. In so ruling, the Second Circuit first concluded the district court incorrectly determined that the plaintiff had not achieved “some success”—a threshold requirement for an ERISA fee award—because … Continue Reading
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
In Wooden v. Alcoa, 2013 WL 141777 (6th Cir. Jan. 11, 2013), the Sixth Circuit ruled that defendant’s claim for reimbursement of benefits overpayments was appropriate equitable relief because defendant’s claim was properly limited to a specified fund within plaintiff’s general assets — the proportion of income that would have been reduced if she had … Continue Reading
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