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Tenth Circuit Rejects 'Make Whole' Relief under ERISA Section 502(a)(3)
Health Plan Law 
Nov. 2, 2006
Excerpt: Joining the Second and Fourth Circuit Courts of Appeal, the Tenth Circuit Court of Appeals rejected an interpretation of Section 502(a)(3) that would allow some form of 'make whole' relief against plan fiduciaries. Lind v. Aetna Health, Inc., 2006 WL 3072606 (C.A.10 (Okla.) (October 31, 2006)
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