WASHINGTON, D.C. - A retirement plan participant who challenged the amount of benefits she received upon the plan's termination did not have a cause of action under the Employee Retirement Income Security Act for the plan fiduciaries' alleged violation of the tax code or reliance on the advice of the plan's legal counsel, the District of Columbia Circuit U.S. Court of Appeals ruled Jan. 7 (Denise M. Clark v. Feder Semo and Bard, P.C., et al., No. 12-7092, D.C. Cir.; 2014 U.S. App. LEXIS 218).