Individual Relief under ERISA Section 502(a)(2) Unavailable to Life Insurance Beneficiary: Sixth Circuit | Practical Law
In Walker v. Federal Express Corp., the US Court of Appeals for the Sixth Circuit held that Section 502(a)(2) of the Employee Retirement Income Security Act (ERISA) does not permit individual recovery of life insurance benefits by a plan beneficiary. The Sixth Circuit concluded that the Supreme Court's holding in LaRue v. DeWolff, Boberg and Associates, Inc., which allowed a 401(k) plan participant to seek relief for an employer's breach of fiduciary duty under Section 502(a)(2), applies only to defined contribution pension plans.