Liu v. Kaiser Permanente Employees Pension Plan for the Permanente Medical Group, Inc.

Summary

The Ninth Circuit affirmed dismissal of Liu’s ERISA claims seeking benefits under the plan’s incorporation of the eligible-designated-beneficiary definition and seeking equitable remedies under ERISA. The court held that the incorporated tax-code provision was not applicable to the defined-benefit plan, and that Liu’s equitable-relief theories were forfeited, duplicative, or unavailable as pleaded. A concurrently filed opinion reverses dismissal of Liu’s separate claim based on substantial compliance with the plan’s beneficiary-designation and benefit-election requirements.