The U.S. Court of Appeals for the Fifth Circuit (whose jurisdiction covers Texas), became the second federal appeals court to reverse established precedent by ruling that make-whole money damages are an available remedy under ERISA, citing the recent Supreme Court decision in Cigna Corp. v. Amara. Prior to Amara, the Fifth Circuit, and others, held that “other equitable relief” permitted under ERISA section 502(a)(3) was limited to traditional equitable remedies, such as injunctions or restitution, and not to make-whole money damages. The Fifth Circuit concluded that its prior precedent had been overruled by Amara and remanded the case back to the district court. Gearlds v. Entergy Services, Inc., No. 12-60451 (5th Cir. Feb. 19, 2013).