These remedies are embodied in Section 502(a) of ERISA, which allows suits to be brought for recovery of benefits that were improperly denied, or to enforce other rights under the statute. But it does not permit awards of compensatory or punitive damages, as would usually be available under state law. In practical terms, this means that if Richard Clarke, after having been denied coverage for hospitalization, had paid for care from his own resources, he could have sued after the fact to recover his expenses, assuming the courts agreed that he had been entitled to coverage. Such a suit, however, would be his only remedy. In a case where care is denied and a bad outcome ensues, ERISA does not provide recovery for pain and suffering, additional medical costs, lost wages, or—in this case—wrongful death (4). In other words, Richard Clarke's family is out of luck.