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Article

White & Case LLP | USA | 9 Dec 2009

Second and Third Circuits rule on breach-of-fiduciary-duty claims based on employer’s oral misrepresentations regarding ERISA benefit plans

On September 30, 2009, the Second Circuit held in Ladouceur v. Credit Lyonnais that the plaintiffs could not prevail on a breach-of-fiduciary-duty claim under ERISA based on oral representations made by their employer purporting to alter an ERISA benefit plan.

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