Justia ERISA Opinion Summaries

The Second Circuit affirmed the district court's award of equitable relief in this Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., action. The court rejected defendants' challenges to the district court's award of equitable relief under section 502(a)(3). The court held that the district court did not err in rejecting defendants' challenge to the timeliness of participants' claims; ordering class-wide relief on participants' section 404(a) claims without requiring individualized proof of detrimental reliance; and concluding that mistake, a prerequisite to the equitable remedy of reformation, had been shown by clear and convincing evidence as to all class members. Finally, the district court did not abuse its discretion by awarding equitable relief. View "Osberg v. Foot Locker, Inc." on Justia Law

Former employees of World Airways challenged the dismissal of their complaint seeking damages for fraud, breach of contract and violation of an employee benefit plan. The Second Circuit agreed with the district court that plaintiffs' state law claims arose under the Railway Labor Act (RLA), 45 U.S.C. 151 et seq., and were thus preempted. Because those claims bear a close resemblance to claims brought pursuant to the Employee Retirement Income Securities Act (ERISA), 29 U.S.C. 1001 et seq., the court found it appropriate to borrow and apply the three‐year statute of limitations set forth in Section 1113 of ERISA rather than the six‐month limitations period the district court borrowed from Section 10(b) of the National Labor Relations Act (NLRA), 29 U.S.C.160(b). Accordingly, the court vacated the dismissal of the RLA claims and remanded for further consideration. The court affirmed in all other respects. View "Pruter v. Local 210’s Pension Trust Fund" on Justia Law