Facts

Stanley Hoffman's late wife was employed by the American Society for Technion-Israel Institute of Technology Inc. (ATS). His wife became seriously ill and was placed on disability leave in November 2007. ATS enrolled Mrs. Hoffman in a First Reliance Standard Life Insurance Co. group insurance policy in November 2007, and a Metropolitan Life Insurance Co. group insurance policy in January 2008.

Hoffman filed suit on behalf of the estate of Mrs. Hoffman against ATS, Metropolitan Life, and First Reliance. Hoffman sought recovery of the life insurance benefits, asserting alternative legal and equitable claims for relief. The defendants moved to dismiss the equitable causes of action.

PLAINTIFF'S CONTENTIONS:
Plaintiff contended that both legal and equitable claims should be permitted prior to discovery because it is not known at the pleading stage whether a legal remedy would provide adequate relief.

Result

The Court granted the defendants' motion to dismiss, finding that because Congress already provided an adequate legal remedy for Employment Retirement Income Security Act (ERISA) actions, Plaintiff was precluded from also seeking equitable relief. Thus, his third and fourth causes of action for equitable estoppel and surcharge were barred.