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Manuel v. Turner Industries Group, LLC, et al., No. 17-30835 (5th Cir. Oct. 1, 2018)

Articles Discussing Case:

Fifth Circuit Opines on when Claims may be Properly Maintained under ERISA § 502(a)(1)(B) Versus § 502(a)(3)

Littler Mendelson, P.C. • November 09, 2018
The U.S. Court of Appeals for the Fifth Circuit recently addressed “the labyrinthine complexities of ERISA law and practice.” Manuel v. Turner Industries Group, LLC, et al., No. 17-30835 (5th Cir. Oct. 1, 2018). In this wide-ranging opinion, the Fifth Circuit highlighted the importance of identifying the underlying purported injury to understand whether an ERISA § 502(a)(3) claim (a claim for equitable relief) is duplicative of a claim that could have been brought under ERISA § 502(a)(1)(B) (a claim to recover benefits or enforce a right under the terms of a plan), in which case it should be dismissed.