Sixth Circuit Says Individual Relief Not Available Under ERISA 502(a)(2)

The beneficiary of a participant’s life insurance policy may not recover individual relief for a plan administrator’s alleged fiduciary breaches, the U.S. Court of Appeals for the Sixth Circuit ruled July 11 in an unpublished decision (Walker v. Federal Express Corp., 6th Cir., 11-5201, 7/11/12).

The beneficiary sued the plan administrator to recover her deceased husband’s life insurance benefits and alleged the plan administrator breached its fiduciary duties by failing to provide adequate notification that the participant needed to convert his group life insurance coverage into an individual life insurance policy.

Judge Eric L. Clay, writing for the ...