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Can Plaintiff Get Relief for Fiduciary Breach?
For Your Benefit 
Nov. 4, 2005
Excerpt: A Seventh Circuit panel that included Judge Easterbrook recently invited an ERISA plaintiff to seek 'make-whole' relief against a fiduciary in McDonald v. Household International, Inc. This has been a vexing issue for plan participants since the Supreme Court's decision in Great-West, which many courts have interpreted to limit severely the kind of relief a participant may obtain from fiduciaries and others.
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