09-804 Cigna Corp. v. Amara

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ERISA
Equity

Although ERISA does not give district courts authority to reform a pension plan, relief is authorized by sec. 502(a)(3), which allows a participant, beneficiary, or fiduciary “to obtain other appropriate equitable relief” to redress violations of ERISA “or the [plan’s] terms.”

This Court has interpreted §502(a)(3)’s phrase “appropriate equitable relief” as referring to “‘those categories of relief’” that, before the merger of law and equity, “‘were typically available in equity.’” Sereboff v. Mid Atlantic Medical Services, Inc. , 547 U. S. 356 . This case—concerning a beneficiary’s suit against a plan fiduciary (whom ERISA typically treats as a trustee) about the terms of a plan (which ERISA typically treats as a trust)—is the kind of lawsuit that, before the merger, could have been brought only in an equity court, where the remedies available were traditionally considered equitable remedies. The District Court’s injunctions obviously fall within this category. The other relief it ordered closely resembles three forms of traditional equitable relief. First, what the court did here may be regarded as the reformation of the plan’s terms, in order to remedy false or misleading information CIGNA provided. The power to reform contracts is a traditional power of an equity court and is used to prevent fraud. Second, the part of the remedy holding CIGNA to its promise that the new plan would not take from its employees previously accrued benefits resembles estoppel, also a traditional equitable remedy. Third, the injunctions require the plan administrator to pay already retired beneficiaries money owed them under the plan as reformed. Equity courts possessed the power to provide monetary “compensation” for a loss resulting from a trustee’s breach of duty, or to prevent the trustee’s unjust enrichment. That surcharge remedy extended to a breach of trust committed by a fiduciary encompassing any violation of duty imposed on that fiduciary.

348 Fed. Appx. 627, vacated and remanded.

09-804 Cigna Corp. v. Amara

Breyer , J.; Scalia , J., concurring

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