Changeflow GovPing Courts & Legal Amara v. Cigna Corp. - Second Circuit Affirms E...
Routine Enforcement Amended Final

Amara v. Cigna Corp. - Second Circuit Affirms ERISA Discovery Denial

Favicon for www.courtlistener.com 2nd Circuit Opinions
Filed
Detected
Email

Summary

The Second Circuit affirmed the District of Connecticut's orders denying a motion for accounting or post-judgment discovery in an ERISA class action brought by Janice C. Amara, Gisela R. Broderick, and Annette S. Glanz against Cigna Corp. and the Cigna Pension Plan. The appeals court applied abuse-of-discretion review for equitable remedies and de novo review for legal conclusions, including the district court's interpretation of earlier orders. The Second Circuit rejected plaintiffs' claim that the district court required a showing of actual noncompliance, instead finding the correct standard is whether plaintiffs raised 'significant questions regarding noncompliance with a court order' sufficient to justify the remedy sought.

“"the question for the Court is whether, as applied here, Plaintiffs have raised 'significant questions regarding noncompliance with a court order' sufficient to justify the remedy sought."”

2d Cir. , verbatim from source
Published by 2d Cir. on courtlistener.com . Detected, standardized, and enriched by GovPing. Review our methodology and editorial standards .

About this source

GovPing monitors 2nd Circuit Opinions for new courts & legal regulatory changes. Every update since tracking began is archived, classified, and available as free RSS or email alerts — 7 changes logged to date.

What changed

The Second Circuit affirmed the District of Connecticut's orders denying plaintiffs' motion for accounting or post-judgment discovery in this ERISA case. The court clarified that the applicable standard for obtaining such equitable remedies is whether plaintiffs have raised 'significant questions regarding noncompliance with a court order' sufficient to justify the remedy sought—not a requirement to demonstrate actual noncompliance. The district court's conclusion that plaintiffs failed to meet this burden was upheld.

For ERISA plan participants and fiduciaries in the Second Circuit, this ruling reinforces the standard for post-judgment discovery motions in equitable relief proceedings. Parties seeking accounting or discovery to enforce prior judgments must demonstrate significant questions of noncompliance rather than actual violations. The non-precedential nature of the summary order limits its broader application, but it provides guidance on the procedural threshold for such motions.

Archived snapshot

Apr 25, 2026

GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.

Jump To

Top Caption Combined Opinion

Support FLP

CourtListener is a project of Free
Law Project
, a federally-recognized 501(c)(3) non-profit. Members help support our work and get special access to features.

Please become a member today.

Join Free.law Now

April 24, 2026 Get Citation Alerts Download PDF Add Note

Amara v. Cigna Corp.

Court of Appeals for the Second Circuit

Combined Opinion

24-2913
Amara v. Cigna Corp.

UNITED STATES COURT OF APPEALS
FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A
SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY
FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1.
WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST
CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION
“SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON
ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the
Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the
24th day of April, two thousand twenty-six.

Present:
DEBRA ANN LIVINGSTON,
Chief Judge,
DENNIS JACOBS,
PIERRE N. LEVAL,
Circuit Judges.


JANICE C. AMARA, GISELA R. BRODERICK, ANNETTE
S. GLANZ, Individually and on behalf of others
similarly situated,

Plaintiffs-Appellants,

v. 24-2913

CIGNA CORP., CIGNA PENSION PLAN,

Defendants-Appellees.


For Plaintiffs-Appellants: CHRISTOPHER J. WRIGHT, HWG LLP, Washington, DC.

Stephen R. Bruce, Stephen R. Bruce Law Office,
Washington, DC.

1
For Defendants-Appellees: A. KLAIR FITZPATRICK (Jeremy P. Blumenfeld, on the
brief), Morgan, Lewis & Bockius LLP, Philadelphia,
PA.

Stephanie R. Reiss, Morgan, Lewis & Bockius LLP,
Pittsburgh, PA.

Michael E. Kenneally, Morgan, Lewis & Bockius LLP,
Washington, DC.

Appeal from the orders of the United States District Court for the District of Connecticut

(Nagala, J.).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

DECREED that the orders of the district court are AFFIRMED.

Plaintiffs-Appellants Janice C. Amara, Gisela R. Broderick, and Annette S. Glanz

(“Plaintiffs”) appeal on behalf of a class from the orders of the United States District Court for the

District of Connecticut (Nagala, J.) denying a motion for accounting or post-judgment discovery

in this Employee Retirement Income Security Act (“ERISA”) case and denying reconsideration.

On appeal, Plaintiffs allege a series of errors by the district court in its denial opinions. The

disputes turn primarily on the interpretation of earlier district court orders issued in this case by

Judge Arterton. We assume the parties’ familiarity with the underlying facts, the procedural

history, and the issues on appeal. See generally Amara v. Cigna Corp., 53 F.4th 241 (2d Cir.

2022).


“We review the district court’s fashioning of equitable remedies under ERISA for abuse of

discretion . . . but review the district court’s findings of fact only for clear error.” Id. at 256

(citation modified). We review legal conclusions de novo, and “[a] district court by definition

abuses its discretion when it makes an error of law.” Koon v. United States, 518 U.S. 81, 100

2
(1996) (citation omitted). In this case, Judge Nagala’s legal conclusions include her

interpretations of Judge Arterton’s orders, which we review de novo. United States v. Spallone,

399 F.3d 415, 423 (2d Cir. 2005) (noting that we review a judge’s interpretation of his own order

for abuse of discretion but his interpretation of another judge’s order de novo).

In both their briefing and oral argument, Plaintiffs claim that the district court required a

showing of actual noncompliance as a prerequisite for Plaintiffs to prevail on their motion. We

disagree. Instead of requiring actual noncompliance, the district court stated that “the question

for the Court is whether, as applied here, Plaintiffs have raised ‘significant questions regarding

noncompliance with a court order’ sufficient to justify the remedy sought.” Amara v. Cigna

Corp., No. 1-cv-02361, 2024 WL 1985904, at *3 (D. Conn. May 6, 2024) (quoting Floyd v. City

of New York, No. 8-cv-1034, 2020 WL 3819566, at *4 (S.D.N.Y. July 8, 2020)).

In its careful and thorough opinions, the district court concluded that Plaintiffs did not meet

their burden under this standard. For substantially the reasons in the district court’s opinions, we

AFFIRM the orders of the district court.

FOR THE COURT:
Catherine O’Hagan Wolfe, Clerk

3

Citations

518 U.S. 81 abuse of discretion standard cited

Get daily alerts for 2nd Circuit Opinions

Daily digest delivered to your inbox.

Free. Unsubscribe anytime.

About this page

What is GovPing?

Every important government, regulator, and court update from around the world. One place. Real-time. Free. Our mission

What's from the agency?

Source document text, dates, docket IDs, and authority are extracted directly from 2d Cir..

What's AI-generated?

The summary, classification, recommended actions, deadlines, and penalty information are AI-generated from the original text and may contain errors. Always verify against the source document.

Last updated

Classification

Agency
2d Cir.
Filed
April 24th, 2026
Instrument
Enforcement
Branch
Judicial
Legal weight
Binding
Stage
Final
Change scope
Substantive
Docket
24-2913

Who this affects

Applies to
Employers Insurers
Industry sector
5241 Insurance
Activity scope
ERISA litigation Post-judgment discovery
Geographic scope
United States US

Taxonomy

Primary area
Employment & Labor
Operational domain
Legal
Compliance frameworks
Dodd-Frank
Topics
Financial Services Securities

Get alerts for this source

We'll email you when 2nd Circuit Opinions publishes new changes.

Free. Unsubscribe anytime.

You're subscribed!