Second Circuit Affirms Denial of Post-Judgment Accounting and Discovery in Long-Running CIGNA Pension Plan Class Action

In Amara v. CIGNA Corp., No. 24-2913, 2026 WL 1113470 (2d Cir. Apr. 24, 2026), the Second Circuit affirmed the District of Connecticut’s denial of class plaintiffs’ motion for an accounting or post-judgment discovery, and the denial of reconsideration, in this long-running ERISA action concerning CIGNA’s cash balance pension plan conversion. The class appealed from orders issued by Judge Nagala interpreting earlier orders entered by Judge Arterton, who had previously presided over the case.

Reviewing the district court’s fashioning of equitable remedies under ERISA for abuse of discretion and its factual findings for clear error, the court reviewed legal conclusions de novo. The panel emphasized that Judge Nagala’s interpretations of Judge Arterton’s prior orders were reviewed de novo, citing United States v. Spallone, 399 F.3d 415, 423 (2d Cir. 2005), for the principle that a judge’s interpretation of another judge’s order receives no deference, in contrast to a judge’s interpretation of her own order.

The class argued that the district court had erroneously imposed a requirement of actual noncompliance as a prerequisite to obtaining the requested relief. The Second Circuit rejected that characterization of the lower court’s reasoning. The district court had instead asked whether plaintiffs had raised significant questions regarding noncompliance with a court order sufficient to justify the remedy sought, quoting Floyd v. City of New York, No. 8-cv-1034, 2020 WL 3819566, at *4 (S.D.N.Y. July 8, 2020). Applying that standard, the district court concluded in careful and thorough opinions that plaintiffs had not carried their burden.

Finding no error in the legal standard applied and substantially adopting the reasoning of the district court, the Second Circuit affirmed.