ERISA-Sixth Circuit Rules That Equitable Relief Is Available When Plan And SPD Conflict

In Pearce v. Chrysler Group, L.L.C. Pension Plan, No. 13-2374 (6th Cir. 2015) (Unpublished Opinion), the plaintiff, Randy Pearce (“Pearce”), was appealing, among other matters, the district court’s finding that the applicable summary plan description (the “SPD”) did not materially conflict with the applicable retirement pension plan (the “Pension Plan”), and therefore any motion to amend the complaint to seek equitable relief under ERISA § 502(a)(3) would be futile. Upon review, the Sixth Circuit Court of Appeals (the “Court”) reversed the district court’s finding.

The Court said that, under ERISA § 502(a)(3), a material conflict between the SPD and the Pension Plan can give rise to a claim for equitable relief. In this case, the Plan requires a participant to be employed at retirement to be eligible for the type of pension benefit Pearce is claiming. The SPD does not contain this requirement. As such, the Pension Plan and SPD are in material conflict, and the district court abused its discretion when it denied Pearce’s motion to add equitable claims under ERISA § 502(a)(3). The Court did not express an opinion on the merits of Pearce’s ERISA § 502(a)(3) claims, other than to state that they are not futile.

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