In Massachusetts Mutual Life Insurance Co. et al. v. Russell, the U.S Supreme Court ruled on a case involving an employee's right to sue for extra-contractual damages under the Employee Retirement Income Security Act (ERISA). The plaintiff, Doris Russell, had her disability benefits terminated by her employer and sued for compensatory and punitive damages beyond what was provided in her benefit plan contract. The court held that ERISA did not provide either express or implied rights to recovery of extra-contractual damages caused by improper or untimely processing of benefit claims. It concluded that ERISA’s civil enforcement provisions were intended primarily as a means for participants and beneficiaries to protect their individual rights, rather than serving as a vehicle for punishing errant plan administrators or deterring administrative abuses.

In the dissenting opinion for Massachusetts Mutual Life Insurance Co. et al. v. Russell, Justice Brennan argued that participants in an employee benefit plan should be able to sue for extra-contractual damages if a fiduciary breaches its duties under ERISA (Employee Retirement Income Security Act of 1974). He contended that the majority's interpretation was too narrow and inconsistent with Congress' intent when it enacted ERISA, which was designed to protect employees' rights in their pension plans by setting high standards of conduct for plan administrators. The justice believed that allowing suits for consequential damages would further this goal by deterring fiduciaries from acting improperly and providing adequate remedies when they do so.