We recently blogged about an infrequent ERISA surprise from the US Supreme Court, in CIGNA v. Amara, and now we have a second ruling from the Supreme Court in that case, granting Amara certioria and remanding. This is a procedural twist that is more interesting to lawyers than employers, but it underscores the point we made about uncertainty in this area: we don't really know what remedies are other "appropriate equitable relief" under ERISA, or know how much exposure employers face regarding their ERISA plans. Establishing procedures for compliance with ERISA's disclosure and other requirements is essential to limiting exposure in an uncertain environment.