title: Health plans--enforcement of right to reimbursement not available under ERISA section 502(a)(3). Great-West Life & Annuity Insurance Company v. Knudson.
abstract: The United States Supreme Court reaffirmed its reluctance "to tamper with [the] enforcement scheme" embodied in ERISA by authorizing remedies not specifically authorized by ERISA's text, and held that section 502(c)(3) does not authorize a plan to bring an action to enforce the plan's reimbursement provisions because recovering monetary damages for reimbursement is not relief typically available in equity and, therefore, is not "other equitable relief" within the meaning of section 502(a)(3). An action to impose personal liability on the Knudsons for a contractual obligation to pay money is an action seeking legal, not equitable, relief and is not authorized by section 502(a)(3).
mesh_terms: D019461:Employee Retirement Income Security Act / Q000331:legislation & jurisprudence*; D007349:Insurance, Health, Reimbursement / Q000331:legislation & jurisprudence*; D008329:Managed Care Programs / Q000331:legislation & jurisprudence*; D014481:United States