Jeffrey Ream v. Jeffrey E. Frey Fulton Bank Laurie L. Frey Fulton Bank’s Empirical Analysis
1997
Citation profile
6 federal appellate · 6 district ·
How this case has been cited
Cited by 30 later decisions — most recently March 2016 · most notably Beddall v. State Street Bank & Trust Co. (1998), Kathryn Strom v. Goldman Sachs & Co Goldman Sachs & Co Supplemental Life Insurance Plan (1999)
6 federal appellate · 6 district ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 26 U.S.C. § 401 (Self-Employed Individuals Tax Retirement Act of 1962) · 28 U.S.C. § 1291 · 28 U.S.C. § 1331 · 29 U.S.C. § 1002 (§ 3 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1104 (§ 404 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1105 (§ 405 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1109 (§ 409 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1132 (§ 502 of the Employee Retirement Income Security Act of 1974)
Relies on Massachusetts Mutual Life Insurance v. Russell · Varity Corporation v. Howe · Bixler v. Central Pennsylvania Teamsters Health & Welfare Fund · Rosen v. Hotel And Restaurant Employees & Bartenders Union Of Phila. · Eddy v. Colonial Life Insurance Co. of America
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 30 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“d. Duty in the absence of a request by the beneficiary. Even if the trustee is not dealing with the beneficiary or the trustee's own account, a trustee is under a duty to communicate to the beneficiary material facts affecting the interest of the beneficiary which he knows the beneficiary does not know and which the beneficiary needs to know for his protection in dealing with a third person with respect to his interest.”
2 later decisions quote this exact passage · from the majority“A fiduciary's duties under ERISA are based both on ERISA, particularly the prudent person standard as set forth in ERISA § 404, 29 U.S.C. § 1104, and on the common law of trusts.”
2 later decisions quote this exact passage · from the majority“'Appropriate equitable relief' generally is limited to traditional equitable relief such as restitution and injunctions rather than money damages . Hein v. FDIC, 88 F.3d 210 , 223-24 & n.11 (3d Cir. 1996)[, cert. denied sub nom. Hein v. McNeil, 519 U.S. 1056 (1997)]. However, ERISA § 502(a)(3) does not 'necessarily bar all forms of money damages.' Id. at 224, n.11. Here, though the district court seemed to treat Ream's complaint as one seeking money damages, Ream sought only to recover his vested interest in the plan which largely reflected his own contributions. [citation omitted] This relief, regardless of the language in the complaint, easily may be characterized as restitution and the [former trustee] does not contend otherwise.”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.