Laurent v. PricewaterhouseCoopers LLP, No. 18-487 (2d Cir. 2019)Annotate this Case
The Second Circuit vacated the district court's dismissal of plaintiffs' claims alleging that the terms of their employee retirement benefits plan violated the Employment Retirement Income Security Act (ERISA). In a prior appeal, the court affirmed the district court's holding that the plan violated the statue and remanded to the district court for consideration of the appropriate relief. On remand, defendants moved on the pleadings under Federal Rule of Civil Procedure 12(c), contending that the relief requested by plaintiffs was unavailable as a matter of law. The district court agreed and granted defendants' motion.
The court held that section 502(a)(3) authorizes district courts to grant equitable relief ‐‐ including reformation ‐‐ to remedy violations of subsection I of ERISA, even in the absence of mistake, fraud, or other conduct traditionally considered to be inequitable. Furthermore, the district court is authorized to grant plaintiffs' proposed remedy of enforcement of the reformed plan under section 502(a)(1)(B). Accordingly, the court remanded for further proceedings.