Court So Holds Notwithstanding the Expansion of the Kinds of Equitable Relief in CIGNA Corp. v. Amara
by Mark S. Thomas & Robert W. Shaw
A federal court has ruled that, although a recent U. S. Supreme Court decision expanded the kinds of equitable remedies available to a plaintiff under ERISA § 502(a)(3), those remedies are still unavailable when the ERISA plaintiff has an adequate remedy to recover plan benefits under ERISA § 502(a)(1)(B). The decision of the U. S. District Court for the District of Maryland in Leach v. Aetna Life Insurance Company, No. WMN-13-2757 (February 5, 2014) [an enhanced version of this opinion is available to lexis.com subscribers], provides valuable guidance on the boundaries of the still-evolving scope of equitable remedies available to ERISA plaintiffs.
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