Central States, Southeast & Southwest Areas Health & Welfare Fund v. Student Assurance Services, Inc., 797 F.3d 512

Central States (an ERISA multi-employer health fund) paid $137,204.88 in medical benefits for thirteen student-athletes also covered by student accident policies issued/processed by Columbian Life, Security Life, and Student Assurance.
Central States sought reimbursement from Student Assurance, asserting the plan’s coordination-of-benefits made the student policies primary.
Student Assurance refused, contending their student accident policies were excess and not liable until Central States exhausted plan benefits.
Central States sued under ERISA § 502(a)(3) (and federal common law), seeking declaratory relief, restitution, and imposition of an equitable lien or constructive trust to secure reimbursement.
The district court dismissed, holding the requested relief was legal (not equitable) and thus not available under § 502(a)(3); the court of appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Central States can obtain restitution/equitable remedies (equitable lien or constructive trust) under ERISA § 502(a)(3) to recover benefits paid	Central States: § 502(a)(3) authorizes equitable relief to enforce plan terms and obtain restitution or an equitable lien against non‑ERISA insurers to reimburse plan payments	Student Assurance: Knudson requires that § 502(a)(3) remedies be those traditionally available in equity; Central States seeks money from insurers’ general assets, which is legal relief not equitable	Court: Claims for restitution and equitable lien/constructive trust are legal in nature because Central States does not trace identified funds or assert title to particular property in insurer possession; relief not available under § 502(a)(3)
Whether declaratory relief is available for past and future reimbursement obligations	Central States: Declaratory judgment can resolve who is primarily liable and permit recovery for past and future claims	Student Assurance: Declaratory relief is a disguised claim for money damages for past payments and future disputes are not ripe absent new injuries or claims	Court: Declaratory relief for past payments is effectively a claim for monetary relief and barred by Knudson; declaratory relief for future claims is unripe because no new injuries/claims were alleged

Great‑West Life & Annuity Ins. Co. v. Knudson, 534 U.S. 204 (2002) (§ 502(a)(3) permits only those equitable remedies traditionally available; restitution is equitable only when traced to particular funds in defendant’s possession)
Central States, Se. & Sw. Areas Health & Welfare Fund v. Gerber Life Ins. Co., 771 F.3d 150 (2d Cir. 2014) (Central States’ restitution and equitable-lien claims are legal, not equitable)
Central States, Se. & Sw. Areas Health & Welfare Fund v. First Agency, Inc., 756 F.3d 954 (6th Cir. 2014) (same conclusion applying Knudson to Central States’ claims)
Central States, Se. & Sw. Areas Health & Welfare Fund v. Health Special Risk, Inc., 756 F.3d 356 (5th Cir. 2014) (declaratory relief for past payments is a disguised monetary claim; future claims unripe)