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Reformation CIGNA Equitable Estoppel

Goodwin

Ninth Circuit Holds that Monetary “Make-Whole” Relief Is Not Available Absent Loss to Plan or Unjust Enrichment for Defendant...

Goodwin on

A Ninth Circuit panel recognized that reformation, equitable estoppel and surcharge were among the “appropriate equitable relief” potentially available under Section 502(a)(3) of ERISA (following dictum in CIGNA Corp. v....more

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