Young v. Verizon Bell Atlantic Cash Balance Plan

Dist. Ct. did not err in granting defendant-plan administrator's counterclaim for equitable reformation of ERISA pension plan to correct scrivener's error in plan's calculation of benefits. Section 502(a)(3) of ERISA authorizes plan administrator to seek equitable reformation of plan, and defendant showed by clear and convincing evidence via plan's drafting history and defendant's course of conduct that plan contained drafting error in calculation formula that did not reflect plan participant's reasonable expectations of benefits.