Reported / Citable
Background
Patrick Sean Hawkins, a Wells Fargo employee and participant in the company’s short-term disability plan, alleged that severe work-related stress, anxiety, and symptoms associated with attention-deficit/hyperactivity disorder left him unable to perform his occupation beginning October 5, 2024. Lincoln National Life Insurance Company, the plan administrator, denied his benefits claim after determining that the medical evidence did not establish a disabling impairment as of that date.
Hawkins sued Wells Fargo, the plan, and Lincoln under ERISA. Count 1 sought recovery of allegedly wrongfully denied benefits under § 502(a)(1)(B). Count 2, pleaded in the alternative, sought equitable relief under § 502(a)(3), including a surcharge against the fiduciaries and declaratory and injunctive relief concerning ERISA’s procedural requirements. Defendants moved under Rule 12(b)(6) to dismiss Count 2 as duplicative.
The Court’s Holding
Magistrate Judge Andrew M. Edison recommended granting the motion and dismissing the § 502(a)(3) claim. Applying Fifth Circuit precedent, the memorandum concluded that a claimant whose alleged injury supports a claim under § 502(a)(1)(B) may not also pursue § 502(a)(3)’s catchall remedy merely because the equitable claim is pleaded in the alternative.
The memorandum focused on the substance of Hawkins’s alleged injury and requested relief rather than the labels attached to them. Hawkins characterized his harm as the denial of benefits, and his requested surcharge included the value of those benefits. His demand for relief addressing allegedly deficient claims procedures likewise did not create an independent § 502(a)(3) claim because § 502(a)(1)(B) provides an avenue to challenge problematic administrative procedures in seeking plan benefits.
Key Takeaways
- In the Fifth Circuit, pleading a § 502(a)(3) claim in the alternative does not preserve it when the alleged injury is remediable under § 502(a)(1)(B).
- Courts examine the underlying injury and substance of the requested relief, not whether a plaintiff labels the remedies equitable or legal.
- A surcharge measured by denied benefits and an injunction concerning benefit-review procedures remain duplicative when the essential injury is the denial of plan benefits.
Why It Matters
The recommendation reinforces the limited, safety-net role of ERISA § 502(a)(3) in Fifth Circuit litigation. A benefits claimant generally cannot maintain a parallel equitable-relief theory based on the same denial by requesting a differently labeled remedy or challenging the procedures used to reach the benefits decision.
The memorandum is a recommendation rather than a final adjudication by the district judge; the parties were given 14 days after service to file objections.