in Varity Corp. could not proceed under § 1132(a)(1) because they were no longer plan beneficiaries, nor under § 1132(a)(2), which does not provide relief for individual beneficiaries, so they “must rely on the third subsection, [§ 1132(a)(3)], or they ha[d] no remedy at all.” Id. at 515. The Court in Variety Corp. explained that “where Congress elsewhere provided adequate relief for a beneficiary’s injury, there will likely be no need for further equitable relief.” Id. Following Varity Corp., the majority of circuits that have decided this issue have held that a breach of fiduciary duty claim cannot stand where a plaintiff has an adequate remedy through a claim for benefits under § 1132(a)(1)(B). See, e.g., Korotynska v. Metro. Life Ins. Co., 474 F.3d 101, 107 (4th Cir.2006) (<HOLDING>); Antolik v. Saks, Inc., 463 F.3d 796, 803 (8th
holding that  1132a1b affords the plaintiff adequate relief for her benefits claim and a cause of action under  1132a3 is thus not appropriate holding that the reinstatement of the right to an election of benefits may be an appropriate equitable remedy under 29 usc  1132a3 holding plaintiff had no claim under  1132a3 because his grievance that benefits were denied is specifically addressed in  1132a1b holding that an individual who brings a lawsuit pursuant to  1132a1b to challenge a denial of disability benefits does not also have a right to a cause of action for breach of fiduciary duty under  1132a3 holding that action to recover erisa benefits under the subject plan are legal in nature and that plaintiff is constitutionally entitled to trial by jury on any claim raised under  1132a1b