Employment Law | Expert Legal Commentary
January 24, 2012
US Airways, Inc. v. McCutchen: Third Circuit Limits ERISA Fiduciary Relief; Allows Equitable Reformation
US Airways, Inc. v. McCutchen
By
Jeremy J. Gray of Zuber & Taillieu
In a split with other circuits, the Third Circuit recently limited relief available to benefit plan administrators under ERISA. In US Airways, Inc. v. McCutchen, 663 F.3d 671 (3d Cir. 2011), the Third Circuit held that the “appropriate equitable relief” available under ERISA § 502(a)(3) to plan administrators can be limited by equitable defenses, such as unjust enrichment. The Court also held that such defenses can override express terms of benefit plans which, would otherwise allow full reimbursement from beneficiaries, regardless of whether the beneficiary was made whole.
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About the Author
Jeremy J. Gray is a Partner of Zuber & Taillieu, focusing on employment law.
Image Credit: ©iStockphoto.com/courtneyk
