573 F. App'x 197
3rd Cir.2014Background
- Central States, SE and SW Areas Health and Welfare Fund (an ERISA plan) paid medical expenses for 19 dependents.
- Insurers Monumental Life and Markel issued primary policies; Bollinger, Inc. administered them and claimed excess coverage.
- Central States sought reimbursement for payments and declaratory relief under ERISA § 502(a)(3) and related remedies.
- District Court dismissed, holding § 502(a)(3) does not authorize monetary recovery; Central States appealed.
- Plan language allegedly designated insurers as primary or excess and authorized recovery of wrongly paid benefits; dispute centers on whether relief is equitable under ERISA.
- Central States’ theory framed as restitution/equitable relief, but the court analyzes whether the relief sought is truly equitable or legal, and whether a contractual basis exists for an equitable lien.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 502(a)(3) permits Central States’ recovery claims. | Central States seeks equitable relief to recover wrongly paid benefits. | Insurers argue the relief is for money damages, not equitable relief. | No; relief is legal, not equitable, under § 502(a)(3). |
| Whether Central States has a valid basis for an equitable lien or similar remedy. | Sought equitable lien or constructive trust to recover payments. | No contract or agreement supports an equitable lien by agreement. | No equitable lien by agreement without an underlying contract. |
Key Cases Cited
- Mertens v. Hewitt Assocs., 508 U.S. 248 (U.S. 1993) (ERISA remedies are limited to those in statute; not implied remedies)
- Great-West Life & Annuity Ins. Co. v. Knudson, 534 U.S. 204 (U.S. 2002) (‘Other appropriate equitable relief’ is limited to traditional equity categories)
- Sereboff v. Mid Atl. Med. Servs., Inc., 547 U.S. 356 (U.S. 2006) (Equitable relief granted only for funds within the plaintiff’s possession/control; lien by agreement context)
- Barnes v. Alexander, 232 U.S. 117 (U.S. 1914) (Contingent-fee contract creates an equitable lien by agreement in certain contexts)
- US Airways v. McCutchen, 133 S. Ct. 1537 (U.S. 2013) (Affirms enforceability of contract-based liens under § 502(a)(3) when appropriate)