Cigna V. Amara's Influence So Far

Law360, New York (July 8, 2013, 1:27 PM EDT) -- It has been over two years since the U.S. Supreme Court's landmark Employee Retirement Income Security Act decision in Cigna Corp. v. Amara, yet courts are only beginning to confront its possible expansion of available equitable remedies. This article will survey Amara's influence on § 502(a)(3) claims brought by individual claimants.

Background

ERISA's civil enforcement provision authorizes three fundamental types of claims by private litigants: a claim for benefits (or clarification of rights) under the plan; a claim for breach of fiduciary duty; and a claim for "other appropriate equitable relief" to enforce the terms of the plan or Title I...

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