Billie Jo Risheim

Oct 6, 2023 | jdsupra.com | Darren E. Nadel |Billie Jo Risheim

The Fourth Circuit weighed in on the complex area of equitable relief under ERISA § 502(a)(3), holding that recovery under an unjust enrichment theory may provide claimants with an alternate path to monetary relief under the statute. The Fourth Circuit departed from the reasoning in CIGNA Corp v. Amara, a 2011 Supreme Court case, holding that plaintiffs seeking monetary relief on a personal, rather than proprietary basis cannot recover under § 502(a)(3).

Oct 5, 2023 | littler.com | Darren E. Nadel |Billie Jo Risheim

The Fourth Circuit weighed in on the complex area of equitable relief under ERISA § 502(a)(3), holding that recovery under an unjust enrichment theory may provide claimants with an alternate path to monetary relief under the statute. The Fourth Circuit departed from the reasoning in CIGNA Corp v. Amara, a 2011 Supreme Court case, holding that plaintiffs seeking monetary relief on a personal, rather than proprietary basis cannot recover under § 502(a)(3).