In the latest chapter of the Amara saga, the Second Circuit recently affirmed the district court’s class-wide order to reform CIGNA’s cash balance plan, as a means to remedy what the district court previously found to be...more
Editor's Overview - As it is well known, in Cigna Corp. v. Amara, 131 S. Ct. 1866 (2011), the U.S. Supreme Court identified several forms of appropriate equitable relief that may be available under Section 502(a)(3) of...more
Yet again, the Court has been called upon to negotiate the juxtaposition between Varity and Amara. According to the Complaint in Biller v. Prudential Ins. Co. and Six Continents Hotels, Inc., 2014 U.S. Dist. Lexis 118577,...more
Following the U. S. Supreme Court’s decision in CIGNA Corp. v. Amara, 131 S. Ct. 1866 (2011), the federal courts have wrestled with the task of defining the scope of remedies for “appropriate equitable relief” under ERISA §...more