United States Ninth Circuit

In an ERISA suit, the district court's grant of summary judgment to the defendants is affirmed, where: 1) reform of the terms of the plan's master documents was not proper on grounds of fraud or mistake; 2) the remedy of surcharge for unjust enrichment was not available, since there was no evidence that the plan's administrative committee gained a benefit by failing to ensure that participants received an accurate summary plan description (SPD); and 3) surcharge for compensatory damages for actual harm was not available, since the plaintiffs did not show that their current positions were any different than they would have been without the inaccurate SPD.

Appellate Information

• Decided 03/16/2012
• Published 03/16/2012

Judges

• Goodwin

Court

• United States Ninth Circuit

Counsel

• For Appellant:
  
• Ellen M. Doyle, Chris C. Scheithauer