On Friday, the Sixth Circuit granted en banc review of Rochow v. Life Insurance Company of North America, 737 F.3d 415 (6th Cir. 2013), a controversial decision holding that a ERISA plaintiff that already recovered his benefit under Section 502(a)(1)(B) could also recover for unjust enrichment under Section 502(a)(3).  The benefit in this case was … Continue Reading