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CIGNA Corporation v. Amara  (09-804) 
ERISA relief is possible without showing detrimental reliance 
Decided May 16, 2011 
[Opinion full text

After CIGNA converted its traditional defined benefit pension plan to a cash balance plan, it issued a summary plan description (SPD) to plan participants. Amara brought a class action claiming that CIGNA's notice of the changes was improper, particularly because the new plan in certain respects provided them with less generous benefits. The District Court held for Amara; the 2nd Circuit affirmed. Although CIGNA argued that the plaintiffs failed to show injury, the District Court found that the participants had shown "likely harm". The District Court then (a) reformed the new plan and (b) ordered CIGNA to pay benefits accordingly.  

The US Supreme Court unanimously vacated the 2nd Circuit judgment, and made two significant holdings: 

(1) Although ERISA §502(a)(1)(B) did not give the District Court authority to reform CIGNA's plan, relief is authorized by §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." Section 502(a)(1)(B) speaks to enforcing a plan's terms, not changing them. And the District Court was not enforcing the SPD because statements in the SPD "do not themselves constitute the terms of the plan for purposes of §502(a)(1)(B)." 

(2) Because §502(a)(3) authorizes "appropriate equitable relief" for violations of ERISA, the relevant standard of harm will depend on the equitable theory by which the District Court provides relief, which it will do on remand. Potential equitable theories include estoppel, reformation, and surcharge. If the remedy is equivalent to estoppel, a showing of detrimental reliance must be shown. If the remedy is reformation, equity courts did not insist on a showing of detrimental reliance. If the remedy is surcharge, there must be a showing of actual harm, which may come from detrimental reliance or from the loss of a right protected by ERISA. To obtain relief via surcharge, a plan participant or beneficiary must show that the violation caused injury, but need show only actual harm and causation, not detrimental reliance. 

Case below: Amara v. CIGNA Corp (2nd Cir 10/06/2009); Amara v. Cigna Corp, 534 F. Supp. 2d 288 (D. Conn. 2008).  
Official docket sheet  
Certiorari granted: June 28, 2010. Justice Sotomayor took no part. 
Oral argument: November 30, 2010. [Transcript] [Audio
The Acting Solicitor General will participate in oral argument in this case. 

Questions presented:   

Whether a showing of “likely harm” is sufficient to entitle participants in or beneficiaries of an ERISA plan to recover benefits based on an alleged inconsistency between the explanation of benefits in the Summary Plan Description or similar disclosure and the terms of the plan itself. 

Certiorari Documents: 

Briefs on the merits: 


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