Mealey's (July 20, 2015, 2:13 PM EDT) -- PHILADELPHIA — A defined benefit plan participant did not have standing to seek monetary equitable relief such as disgorgement or restitution under Employee Retirement Income Security Act Section 502(a)(3) based on an increased risk of plan default, and a federal district court did not abuse its discretion in denying attorney fees even though the participant achieved some success under the catalyst theory, the Third Circuit U.S. Court of Appeals affirmed July 13 (Jeffrey E. Perelman v. Raymond G. Perelman, Nos. 14-1663, 14-2742, 3rd Cir.; 2015 U.S. App. LEXIS 12022)....