Egbers v. Senior Lifestyle Corporation, 1:16-cv-00732

Senior Lifestyle Corporation (Defendant) established a self-funded employee health Plan in 2002; payroll-deducted employee contributions were retained by Defendant then remitted to third-party administrator Key Benefits Administrators, Inc. (KBA).
In 2015 Defendant allegedly failed to remit employee and employer contributions to KBA, leaving the Plan underfunded and claims unpaid.
Plaintiffs Egbers and Williams (both pregnant during the relevant period) allege medical claims were not paid due to the funding shortfall; alleged out-of-pocket expenses of ~$2,500 (Egbers) and ~$400,000 (Williams).
Plaintiffs allege Defendant told employees it was addressing the “2015 KBA claims issue” but claims remain unpaid and plaintiffs face collections.
Plaintiffs filed this putative class action alleging ERISA violations, including breach of fiduciary duty under 29 U.S.C. § 1132(a)(3) and denial-of-benefits under § 1132(a)(1)(B). Defendant moved to dismiss the amended complaint under Rule 12(b)(6).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiffs may pursue an ERISA §502(a)(3) breach-of-fiduciary-duty claim rather than only a §502(a)(1)(B) benefits claim	Plaintiffs contend the injury is distinct: Defendant breached fiduciary duties by failing to remit contributions, risking ongoing plan insolvency and seeking classwide injunctive relief plus benefits	Defendant argues plaintiffs merely repackaged a benefits claim; relief is available only under §502(a)(1)(B), so §502(a)(3) is inappropriate and duplicative	Court denied dismissal: plaintiffs plausibly allege a distinct fiduciary injury and seek injunctive, classwide relief under §502(a)(3) (dismissal denied)
Whether plaintiffs stated a §502(a)(1)(B) denial-of-benefits claim	Plaintiffs seek benefits for unpaid claims due to the funding failure	Defendant argues the complaint fails to state a claim for denial of benefits	Court declined to decide §502(a)(1)(B) claim after finding §502(a)(3) claim adequately pleaded

Varity Corp. v. Howe, 516 U.S. 489 (1996) (clarifies when equitable relief under §502(a)(3) is available and relation to other ERISA remedies)
Wilkins v. Baptist Healthcare System, Inc., 150 F.3d 609 (6th Cir. 1998) (discusses proper use of §502(a)(1)(B) for benefit denials versus §502(a)(3))
Hill v. Blue Cross and Blue Shield of Mich., 409 F.3d 710 (6th Cir. 2005) (upholds §502(a)(3) claim where defendant’s plan-wide practice required injunctive relief beyond individual benefit awards)
Rochow v. Life Ins. Co. of N. Am., 780 F.3d 364 (6th Cir. 2015) (dismissed duplicative §502(a)(3) claims where plaintiff recovered all wrongly denied benefits under §502(a)(1)(B))
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard for plausibility)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (pleading standard requiring more than formulaic allegations)
Tackett v. M&G Polymers, USA, LLC, 561 F.3d 478 (6th Cir. 2009) (applying plausibility standard in ERISA context)
Bassett v. Nat’l Collegiate Athletic Ass’n, 528 F.3d 426 (6th Cir. 2008) (rules for construing complaints on motion to dismiss)