CINCINNATI - The Sixth Circuit U.S. Court of Appeals ruled 2-1 on Dec. 6 that a disability plan participant who was awarded benefits under Employee Retirement Income Security Act Section 502(a)(1)(b) was also entitled to an equitable award of $3.79 million in disgorged profits under Section 502(a)(3) (Todd R. Rochow, et al. v. Life Insurance Company of North America, No. 12-2074, 6th Cir.; 2013 U.S. App. LEXIS 24271).