## Facts

- CIGNA maintained a traditional defined-benefit pension plan that paid an annuity based on pre-retirement salary and service.
- In 1998, CIGNA converted the plan to a cash-balance plan that credited annual contributions plus compound interest and translated accrued benefits into an opening cash-balance amount.
- Plan participants alleged the new plan was less generous in certain respects and that CIGNA’s notices and disclosures were inaccurate or incomplete.
- Participants claimed violations of ERISA disclosure requirements governing summary plan descriptions (SPDs), summaries of material modifications, and notice obligations related to benefit reductions.
- The district court found ERISA disclosure violations and concluded the notice failures caused “likely harm” to participants.
- As relief, the district court reformed the amended plan and ordered payment of benefits under the plan as reformed, treating the remedy as authorized by ERISA § 502(a)(1)(B).
- The Second Circuit affirmed, and the Supreme Court granted review.

## Issues

1. Whether ERISA § 502(a)(1)(B) authorizes a court to reform a pension plan’s terms and then award benefits under the reformed plan.
2. Whether ERISA § 502(a)(3) authorizes plan reformation and related monetary remedies as “other appropriate equitable relief” for disclosure violations.
3. What showing of harm is required to obtain equitable relief for misleading or deficient plan communications, including whether individualized detrimental reliance is required.

## Decision

- The Court vacated the judgment and remanded.
- ERISA § 502(a)(1)(B) does not authorize plan reformation; it permits enforcement of existing plan terms and recovery of benefits due under those terms.
- SPDs and similar disclosures are not themselves plan terms enforceable under § 502(a)(1)(B).
- ERISA § 502(a)(3) can authorize equitable remedies, including reformation, surcharge (make-whole monetary relief against a breaching fiduciary), and estoppel, depending on the equitable theory and its elements.
- The required showing of harm is determined by the equitable remedy sought; the Court rejected a categorical requirement that each participant prove individualized detrimental reliance for the equitable remedies discussed.

## Legal Principles

- Section 502(a)(1)(B) provides legal relief to recover benefits due and enforce rights under the terms of the plan; it does not empower courts to alter plan terms.
- Disclosures such as SPDs are required by ERISA but are not automatically part of the plan’s terms; misleading disclosures may support relief, but not by treating the SPD as the plan itself.
- Section 502(a)(3) authorizes “appropriate equitable relief” to redress ERISA violations or violations of plan terms, including equitable reformation of plan documents where equity’s requirements are met.
- Equity historically permits surcharge against fiduciaries for breach of duty, measured by the beneficiary’s loss or the fiduciary’s gain, and such monetary relief can qualify as equitable under § 502(a)(3).
- The harm or prejudice showing for equitable relief depends on the specific equitable cause of action; detrimental reliance is not uniformly required.

## Conclusion

The Court held that participants could not obtain plan reformation through ERISA § 502(a)(1)(B), and that SPDs are not enforceable as plan terms under that provision; instead, equitable remedies such as reformation and surcharge may be available under § 502(a)(3), with the required showing of harm governed by traditional equitable standards rather than a universal individualized reliance requirement.


Cigna Corp. v. Amara, 563 U.S. 421 (2011)