Sixth Circuit: Todd Rochow v. Life Ins. Co. of North America

Where plaintiff is made whole by reversal of ERISA decision, further statutory relief by means of equitable disgorgements of profits is unnecessary and duplicative.

Concurrence: absent formal remand after earlier appeal, subsequent litigation of subsidiary issues in the lower court might have been barred by the Mandate Rule.

Concur/Dissent: Case for disgorgement not proven.

Dissent: Breach of Fiduciary Duty claim was distinct from Denial of Benefits claim, and the second injury justifies the second relief.

Todd Rochow v. Life Ins. Co. of North America