The Ninth Circuit Opens The Door To Additional Defendants In 502(a)(1)(B) Cases

Recently, in Cyr v. Reliance Standard Life Ins. Co., Nos. 07-56869, 08-55234 (9th Cir. June 22, 2011), the Ninth Circuit ruled that in an action for benefits brought pursuant to Section 502(a)(1)(B) of ERISA, entities other than the plan, plan administrator, or trustee can be named as proper defendants.  This decision overrules prior precedent and clarifies dicta in which the Ninth Circuit held that only these entities were proper defendants. 

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