Georgia Federal Judge Says Beneficiary Has Adequate Remedy Under ERISA

(March 1, 2017, 4:29 PM EST) -- ATLANTA — Because a beneficiary seeking supplemental life insurance benefits for a plan participant’s disability has an adequate remedy under Section 502(a)(1)(B) of the Employee Retirement Income Security Act and failed to provide support for a separate breach of fiduciary duty claim, a Georgia federal judge on Feb. 27 dismissed the breach of fiduciary claim alleged against the plan (Stephanie D. Vaughn v. Aetna Life Insurance Co., No. 16-1107, N.D. Ga., 2017 U.S. Dist. LEXIS 26743)....

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