Court Holds That ERISA Plaintiff Cannot Claim Equitable Remedies When the Plaintiff Has Adequate Remedies to Recover Plan Benefits, Notwithstanding the Expansion of the Kinds of Equitable Relief in CIGNA Corp. v. Amara
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), provides valuable guidance on the boundaries of the still-evolving scope of equitable remedies available to ERISA plaintiffs.
The Background. The plaintiff (Leach) was the wife of an employee of Owens-Corning Corporation. Her husband was enrolled under a group life insurance policy sponsored by Owens-Corning and administered by the defendant, Aetna Life Insurance Company (Aetna). Leach was named as the beneficiary under her husband’s coverage. The policy provided that coverage could continue after an employee’s Owens-Corning employment if, upon retirement, the employee had reached the age of 55 and completed 10 years of Owens-Corning employment. Leach’s husband met both of those requirements, and retired in 2003. Owens-Corning did not inform Aetna of that change in his employment status. Six years later, Leach’s husband contacted Aetna to confirm his coverage under the policy and apparently did not reveal his retirement. Based on its records, which still showed the husband as employed by Owens-Corning, Aetna verified the coverage. After receiving that verification, the husband cancelled another life insurance policy. He died in 2012.
