Sixth Circuit Rejects Claim that Disgorgement of Profits Is Appropriate Remedy in ERISA Benefit Denial Action

By and on March 31, 2015

On March 5, 2015, the U.S. Court of Appeals for the Sixth Circuit reversed the finding of a prior Sixth Circuit panel that allowed successful plaintiffs to recover additional equitable relief in the form of disgorgement of profits under a return-on-equity analysis in addition to the recovery of the denied benefits. This decision realigns the Sixth Circuit with the other circuits by requiring that plaintiffs prove a separate injury in order to receive additional equitable relief under ERISA.

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Michael T. Graham

Patrick Ryan
Patrick D. Ryan focuses his practice on employee benefits & executive compensation matters unique to business transactions as well as generalized qualified plan matters. Patrick also has experience with health and welfare benefits.Read Patrick D. Ryan's full bio.




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