ERISA action need not identify the specific language of every plan provision at issue to state a claim, so long as the pleading is not overly conclusory; the suit might be resolved using representative terms.
Under state law, similar analysis applied to the claim for breach of contract.
As a suit for monetary damages is possible, a suit for breach of fiduciary duty is barred by the statute and precedent.
No error in denial of leave to amend second amended complaint, as the request did not discuss the legal standard for untimely leave to amend.
http://www.ca5.uscourts.gov/opinions/pub/14/14-11300-CV0.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.