Massachusetts Mutual Life Insurance Co. v. Russell

473 U.S. 134 (1985)

From our private database of 46,300+ case briefs, written and edited by humans—never with AI.

Massachusetts Mutual Life Insurance Co. v. Russell

United State Supreme Court
473 U.S. 134 (1985)

  • Written by Alexander Hager-DeMyer, JD

Facts

Doris Russell (plaintiff) was an employee of Massachusetts Mutual Life Insurance Company (Mutual) (defendant). Russell was a beneficiary under two employee benefit plans administered by Mutual, funded by the company’s general assets, and governed by the Employee Retirement Income Security Act (ERISA). Russell was disabled due to back problems and was paid benefits until October 1979. The benefits were cancelled on a surgeon’s recommendation, and Russell requested review of the decision. Russell submitted a psychiatrist’s testimony that she had a psychosomatic disability. Mutual reinstated benefits in March 1980 and paid contractual retroactive benefits dating back to October 1979. Russell sued in California state court for damages caused by the denial of benefits from October 1979 to March 1980. Russell stated that during the coverage gap, her husband was forced to deplete his retirement savings, aggravating her psychological ailment. Russell asserted that the 132-day delay in processing her claim violated Mutual’s fiduciary duty under ERISA and provided causes of action under § 409(a) that could be claimed by plan beneficiaries under § 502(a)(2). Mutual removed the case to federal district court, which granted summary judgment in favor of Mutual. Russell appealed to the United States Court of Appeals for the Ninth Circuit, which reversed the judgment as to the ERISA claims. The court of appeals found that ERISA authorized extracontractual damages for Russell in §§ 409(a) and 502(a)(2) as appropriate equitable relief that followed the legislative intent behind ERISA. Mutual appealed to the United States Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Stevens, J.)

Concurrence (Brennan, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 807,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 807,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 807,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,300 briefs - keyed to 988 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership