## Facts

- Doris Russell, an employee of Massachusetts Mutual Life Insurance Company and a beneficiary under its ERISA-governed disability plan, became disabled in May 1979 and began receiving long-term disability benefits.
- The plan’s disability committee terminated her benefits on October 17, 1979, based on an orthopedic surgeon’s report.
- Russell sought internal review and submitted additional medical material, including support for psychosomatic/psychological disability.
- On March 11, 1980, the plan administrator reinstated her benefits and paid retroactive benefits in full.
- Russell alleged that the 132-day period without benefits caused financial strain and worsened her condition, and she sued alleging, among other claims, breach of ERISA fiduciary duties based on improper or untimely claims processing.
- The federal district court granted summary judgment for the plan administrator, concluding ERISA barred claims for extracontractual damages tied to the benefit denial.
- The Ninth Circuit reversed in relevant part, holding that a beneficiary could recover damages under ERISA § 409(a) through § 502(a)(2) for the delay.
- The Supreme Court granted review.

## Issues

1. Whether ERISA § 409(a), enforceable through § 502(a)(2), permits an individual beneficiary to recover extracontractual damages (including consequential or punitive damages) for injuries caused by improper or untimely processing of benefit claims.

## Decision

- The Supreme Court reversed the Ninth Circuit and reinstated summary judgment for Massachusetts Mutual.
- The Court held that ERISA § 409(a) does not authorize a beneficiary to obtain extracontractual damages for personal injuries stemming from delayed or improper benefit-claim processing.
- The Court reasoned that § 409(a)’s remedies are directed to “the plan” (making good losses to the plan, restoring profits to the plan, and comparable relief), not to individualized damage awards.
- The Court relied on ERISA’s detailed civil-enforcement scheme in § 502(a) as evidence that courts should not infer additional remedies beyond those Congress expressly provided.
- A concurrence agreed in the judgment and suggested that other ERISA provisions (not § 409(a)/§ 502(a)(2)) might support different forms of equitable relief in appropriate cases.

## Legal Principles

- Relief under ERISA § 409(a) is plan-focused: a breaching fiduciary is liable to make good losses to the plan and restore profits to the plan; it does not create a personal damages remedy for beneficiaries.
- A claim brought under ERISA § 502(a)(2) for “appropriate relief under § 409” must seek relief that benefits the plan as an entity, not individualized extracontractual compensation.
- ERISA’s “carefully integrated” enforcement provisions in § 502(a) counsel against judicial creation of additional remedies not expressly authorized.
- Trust-law background supports viewing fiduciary-breach remedies as designed to protect the plan (as a common fund) rather than to award consequential or punitive damages to individual beneficiaries.

## Conclusion

The Court held that ERISA § 409(a), enforced through § 502(a)(2), provides remedies for losses to the plan and comparable plan-level relief, not extracontractual damages payable to an individual beneficiary for harms allegedly caused by delayed processing of benefit claims.


Massachusetts Mut. Life Ins. Co. v. Russell, 473 U.S. 134 (1985)