Guerra-Delgado v. Banco Popular de Puerto Rico

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• recognizing that “many of our sister circuits have recognized equitable estoppel claims under 502(a)(3)(B)” but declining to consider whether the claims are cognizable
• recognizing that an equitable estoppel claim under ERISA “is necessarily limited to statements that interpret the plan and cannot extend to statements that would modify the plan”
• noting that plans must “provide a procedure for amending the plan, and modifications made in contravention of the plan’s stated procedure violate that requirement”
• observing that courts are more willing to grant equitable estoppel with respect to “statements that interpret the plan” as opposed to “statements that would modify the plan” (emphasis in original)
• explaining that ERISA requires plans to inhere in a written instrument with a stated amendment procedure, such that a plan may not be modified outside of the instrument and in contravention of the procedure
• affirming summary judgment and holding that because “[plaintiff] has not shown any ambiguity in the Plan, his equitable estoppel claim necessarily fails”

Source: CourtListener parenthetical corpus (CC0).