Convergex Group, LLC v. Fletcher

Whether a participant in a defined-benefit ERISA plan may claim "representational" standing and rely on only his plan's injuries to satisfy article III's standing requirement, as the U.S. Court of Appeals for the 2nd Circuit has held; or whether the participant must establish his own article III standing to proceed, as the U.S. Courts of Appeals for the 3rd, 4th, 5th, 6th, 8th, and 9th Circuits have held.