LaRue v. DeWolff, Boberg & Associates, Inc.
United States Supreme Court
552 U.S. 248 (2008)
Relevant factsFree
LaRue (plaintiff) instructed DeWolff (defendant), his plan administrator, to change his individual retirement-account investments, but DeWolff never made the changes, allegedly depleting his account by about $150,000; DeWolff argued that under Massachusetts Mutual Life Ins. Co. v. Russell, ERISA § 502(a)(2) permits suits only on behalf of the plan as a whole, not for harm to an individual account, and the district court and Fourth Circuit agreed, dismissing LaRue's suit.
IssueFree
Whether, under section 502(a)(2) of ERISA, a participant in a defined-contribution plan may recover for fiduciary breaches that impair the value of plan assets in the participant's individual account.