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David Ogden and Camilla Ogden v. Blue Bell Creameries U.S.A., Inc.
Date: 10-28-2003
Case Number: 02-16733
Judge: Dubina
Court: United States Court of Appeals for the Eleventh Circuit
Plaintiff's Attorney: Unknown
Defendant's Attorney: Unknown
This case presents us with the question of whether a plaintiff may seek
equitable relief under Section 502(a)(3) of the Employment Retirement Income
Security Act of 1974 ("ERISA"), 29 U.S.C. § 1132(a)(3), when the doctrine of res
judicata bars his Section 502(a)(1)(B), 29 U.S.C. § 1132(a)(1)(B), claim for
recovery of benefits due under a welfare benefits plan. The district court found
that Appellees David and Camilla Ogden were entitled to equitable relief under
Section 502(a)(3), and a corresponding award of attorney's fees under Section
502(g)(1), 29 U.S.C. § 1132(g)(1), even though their Section 502(a)(1)(B) claim to
recover payment under Appellant Blue Bell Creameries USA, Inc.'s ("Blue
Bell's") Welfare Benefits Plan (the "Plan") was barred by an earlier action that
was resolved against them in an Alabama state court. We hold that an ERISA
plaintiff has no cause of action under Section 502(a)(3) where Congress provided
for an adequate remedy elsewhere in the ERISA statutory framework, even if res
judicata now bars the adequate remedy provided. Accordingly, we reverse the
district court's awards of Section 502(a)(3) relief and vacate the award of
attorney's fees.
* * *
Click the case caption above for the full text of the Court's opinion.
because Congress provided them with an adequate remedy elsewhere in the
ERISA statutory framework. Accordingly, we reverse the district court’s award of
equitable relief and vacate the award of attorney’s fees. Because both parties have
requested attorneys’ fees, we remand this case solely for a determination of
whether either party is entitled to a fee award in light of our holding.
Digested by Kent Morlan
About This Case
What was the outcome of David Ogden and Camilla Ogden v. Blue Bell Creameries U.S...?
The outcome was: We hold that the Ogdens had no cause of action under Section 502(a)(3) because Congress provided them with an adequate remedy elsewhere in the ERISA statutory framework. Accordingly, we reverse the district court’s award of equitable relief and vacate the award of attorney’s fees. Because both parties have requested attorneys’ fees, we remand this case solely for a determination of whether either party is entitled to a fee award in light of our holding.
Which court heard David Ogden and Camilla Ogden v. Blue Bell Creameries U.S...?
This case was heard in United States Court of Appeals for the Eleventh Circuit, AL. The presiding judge was Dubina.
Who were the attorneys in David Ogden and Camilla Ogden v. Blue Bell Creameries U.S...?
Plaintiff's attorney: Unknown. Defendant's attorney: Unknown.
When was David Ogden and Camilla Ogden v. Blue Bell Creameries U.S... decided?
This case was decided on October 28, 2003.