Supreme Court of the United States
Cigna Corp. v. Amara
May 16, 2011563 U.S. 421
Summary
The Court held that ERISA §502(a)(1)(B)—which lets participants recover benefits due under their plan's terms—did not authorize the District Court to reform CIGNA's cash-balance plan, because that provision enforces plan terms rather than changing them and summary plan descriptions are communications about the plan, not plan terms. The relief ordered nonetheless fell within §502(a)(3)'s 'appropriate equitable relief': reformation of the plan's benefit guarantee, estoppel-like enforcement of CIGNA's promises, and surcharge-style payment of benefits owed are traditional equitable remedies available against a plan fiduciary. On the harm-standard question, the Court held the measure of injury must be borrowed from equitable principles—a remedy equivalent to estoppel requires detrimental reliance, but surcharge for §§102(a) and 104(b) violations requires only actual harm and causation, not necessarily detrimental reliance—and it vacated and remanded for the District Court to analyze relief under §502(a)(3) in the first instance. Justice Scalia, concurring in the judgment and joined by Justice Thomas, agreed an SPD is not part of the plan but would have gone no further, branding the Court's §502(a)(3) discussion unbriefed dicta.
Holding
- Whether ERISA §502(a)(1)(B) authorized the District Court to reform CIGNA's plan and award benefits on that basis.. No. §502(a)(1)(B) speaks of enforcing the terms of the plan, not changing them, and the statements in summary plan descriptions do not themselves constitute terms of the plan; the District Court could not find authority in that section to reform CIGNA's plan as written.
- Whether the relief the District Court ordered falls within 'appropriate equitable relief' under ERISA §502(a)(3).. Yes. The affirmative and negative injunctions obviously qualify, and the remaining relief closely resembles three forms of traditional equitable relief: reformation of the plan's terms to remedy false or misleading information, estoppel-like enforcement of CIGNA's promise that the new plan would not take previously accrued benefits, and surcharge—monetary compensation for loss resulting from a trustee's breach of duty or to prevent unjust enrichment.
- What standard of harm governs equitable relief under §502(a)(3) for violations of ERISA's disclosure provisions.. The relevant standard of harm depends on the equitable theory by which relief is provided. When a court imposes a remedy equivalent to estoppel, detrimental reliance must be shown; but to obtain relief by surcharge for violations of §§102(a) and 104(b), a participant or beneficiary need show only actual harm and causation—not detrimental reliance—with actual harm proved by a preponderance of the evidence, since the harm may consist of the loss of a right protected by ERISA or its trust-law antecedents.
Docket 09-804
Cited authorities
- 29 U.S.C. §§1022
- 29 U.S.C. §§1022
- 29 U.S.C. §§1002
- 29 U.S.C. § 1024(b)
- 29 U.S.C. § 1054(h)
- 29 U.S.C. § 1024(b)
- 29 U.S.C. § 1021(a)
- 29 U.S.C. § 1022
Cited by
- Noah U., an Individual v. Tribune Company Medical Plan and Blue Cross Blue Shield of Illinois
- James L. Bush v. Liberty Life Assurance Company of Boston
- Jackson v. Personal Representative of Donald Comb
- Bowers v. Russell
- Lawrence Merigan v. Liberty Life Assurance Company of Boston
- Sharon Prouty v. the Hartford Life and Accident Insurance Co. and C & S Wholesale Grocers Inc.
- Lawrence Merigan v. Liberty Life Assurance Company of Boston
- Schwartz v. Keolis Commuter Services, LLC.