ATLANTA - Under the Employee Retirement Income Security Act, a corporate employer undergoing bankruptcy reorganization cannot pursue an action for the benefit of its bankruptcy estate and, thus, its unsecured creditors against the employer's former owner for liabilities arising from the termination of a pension plan, the 11th Circuit U.S. Court of Appeals affirmed Jan. 7 (Durango-Georgia Paper Co., et al. v. H.G. Estate, LLC, et al., No. 11-15079, 11th Cir.; 2014 U.S. App. LEXIS 251).