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Keywords

contracttortliabilityequitycontractual obligationspecific performancerestitutionequitable relief
contractliabilityequitycontractual obligationspecific performanceequitable relief

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Great-West Life & Annuity Ins. Co. v. Knudson, 534 U.S. 204, 122 S.Ct. 708, 151 L.Ed.2d 635, 70 USLW 4056, 27 Employee Benefits Cas. 1065, 02 Cal. Daily Op. Serv. 142, 2002 Daily Journal D.A.R. 187, Pens. Plan Guide (CCH) P 23976R, 15 Fla. L. Weekly Fed. S 53

Facts

Janette Knudson was injured in a car accident, and her health plan covered $411,157.11 of her medical expenses. The plan included a reimbursement provision allowing it to recover any payments made to a beneficiary from third-party recoveries. After settling a state-court tort action for $650,000, the Knudsons allocated $13,828.70 to satisfy the plan's reimbursement claim. Great-West Life & Annuity Insurance Co. filed a federal action to enforce the reimbursement provision, seeking to compel the Knudsons to pay the full amount of benefits paid, despite the state court's determination of the reimbursement amount.

Janette Knudson was injured in a car accident, and her health plan covered $411,157.11 of her medical expenses. The plan included a reimbursement provision allowing it to recover any payments made to a beneficiary from third-party recoveries.

Issue

Does § 502(a)(3) of the Employee Retirement Income Security Act authorize a plan to bring an action for specific performance of a reimbursement provision against a beneficiary who has recovered from a third party?

Does § 502(a)(3) of the Employee Retirement Income Security Act authorize a plan to bring an action for specific performance of a reimbursement provision against a beneficiary who has recovered from a third party?

Rule

The term 'equitable relief' in § 502(a)(3) refers to categories of relief typically available in equity, and does not include actions seeking to impose personal liability for a contractual obligation to pay money.

The term 'equitable relief' in § 502(a)(3) refers to categories of relief typically available in equity, and does not include actions seeking to impose personal liability for a contractual obligation to pay money.

Analysis

The Court analyzed the nature of the relief sought by Great-West and determined that it was essentially seeking to impose personal liability on the Knudsons for a contractual obligation, which is a form of legal relief not typically available in equity. The Court distinguished between legal and equitable forms of restitution, concluding that the relief sought was legal in nature, as it aimed to recover a specific sum of money rather than restore particular funds or property.

The Court analyzed the nature of the relief sought by Great-West and determined that it was essentially seeking to impose personal liability on the Knudsons for a contractual obligation, which is a form of legal relief not typically available in equity.

Conclusion

The Supreme Court affirmed the lower court's decision, holding that the action was not authorized under § 502(a)(3) because it sought legal relief rather than equitable relief.

The Supreme Court affirmed the lower court's decision, holding that the action was not authorized under § 502(a)(3) because it sought legal relief rather than equitable relief.

Who won?

The Knudsons prevailed in the case because the Supreme Court determined that the action brought by Great-West was not authorized under ERISA, as it sought legal relief rather than equitable relief.

The Knudsons prevailed in the case because the Supreme Court determined that the action brought by Great-West was not authorized under ERISA, as it sought legal relief rather than equitable relief.

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