LaRue v. DeWolff, Boberg & Associates, Inc.

Summary

The Supreme Court held that ERISA § 502(a)(2) authorizes a participant in a defined contribution plan to seek recovery for fiduciary breaches that impair the value of assets in the participant’s individual account, provided the injury is a plan injury rather than an injury distinct from harm to the plan. The Court vacated the Fourth Circuit’s judgment and remanded the case. Concurring opinions discussed whether the claim might instead proceed under ERISA § 502(a)(1)(B) and emphasized that recovery under § 502(a)(2) is for the plan.

Holdings

1. Although § 502(a)(2) does not provide a remedy for individual injuries distinct from injuries to the plan, it authorizes recovery for fiduciary breaches that impair the value of plan assets in a participant's individual account.
2. The Court did not decide whether petitioner's requested make-whole relief was equitable relief available under ERISA § 502(a)(3), because it resolved the case under § 502(a)(2).

Questions Presented

1. Whether ERISA § 502(a)(2) authorizes a plan participant in a defined-contribution plan to recover for fiduciary misconduct that impairs the value of assets in the participant's individual account.
2. Whether the Court should decide whether the asserted make-whole relief is equitable relief under ERISA § 502(a)(3).

Disposition

vacated