The United States Supreme Court in Larue v. DeWolff, Boberg & Associates, Inc. February 20 ruled that although Section 502(a)(2) of the Employee Retirement Income Security Act of 1974 (ERISA) generally does not provide a remedy for individual injuries distinct from plan injuries in plans providing ?fixed benefits,? ERISA ? 502(a) does allow individual participants to seek to recover individually from fiduciaries for lost value to plan assets in a participant\’s individual account resulting from a fiduciary breach.