Mealey's (October 10, 2016, 1:52 PM EDT) -- LOS ANGELES — A California appeals panel held Oct. 6 that monetary relief for extracontractual harm is legally recoverable under Section 502(a)(3) of the Employee Retirement Income Security Act, reversing a lower court’s ruling that insurers have no duty to defend a managed care company against underlying lawsuits (Health Net, Inc. v. American International Specialty Lines Insurance Co., et al., No. B262716, Calif. App., 2nd Dist., Div. 3; 2016 Cal. App. Unpub. LEXIS 7296)....