Crotty

Appellants John T. Crotty and his wife, Suzanne S. Crotty, appeal the district court’s grant of summary judgment in favor of Appellees. John Crotty, an attorney, participated in the “profit sharing plan” and the “money purchase plan” (together the “Plans”) at the law firm where he worked. He contends that the administrator of the Plans withheld his ERISA benefits and failed to provide certain requested information, in- *543 eluding copies of summary plan descriptions, as required by ERISA. Crotty seeks to recover his ERISA benefits under 29 U.S.C. § 1132 (a), and he seeks statutory damages under 29 U.S.C. § 1132 (c) for the plan administrator’s failure to provide certain requested information.

The district court granted summary judgment in favor of Appellees concluding that Crotty lacked ERISA standing because during the district court litigation he received all of his vested benefits under the Plans. The district court also ruled that Crotty was not entitled to damages under § 1132(c) for the plan administrator’s failure to provide information because Crotty never requested the information in writing.

We conclude that even if Crotty did receive his vested benefits during the…