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The Eighth Circuit Provides for Equitable Relief Under ERISA

A new decision entitled Silva v. Metropolitan Life issued on August 7, 2014, clarifies when equitable relief may be available under ERISA.  Silva was the beneficiary of a life insurance policy MetLife had issued to his son.  After accepting premiums on the policy, MetLife found that the policy had been issued in error because the insured had never filled out a health form questionnaire, which MetLife argued was required because the policy amount was more than three times the applicant’s salary.  The district court granted summary judgment to MetLife but ordered that approximately $126 in premiums be refunded.  On appeal the Eight Circuit reversed finding that the plaintiff could state a claim for equitable relief and that the following three remedies of (1) surcharge; (2) reformation; and (3) estoppel were available to the claimant.  This opinion is one more decision since the Supreme Court’s groundbreaking opinion in Amara v. Cigna.