Great-West Life & Annuity Insurance Co. v. Knudson

Summary

U.S. Supreme Court

        Janette Knudson was injured in a car accident. The health plan covered $411,157 of medical expenses paid by Great-West Life & Annuity Insurance Co. Great-West was assigned the plan's right to recover from a beneficiary payments for benefits that were recovered from a third party. From a tort action, Knudson obtained a settlement allocated to attorney fees, a medical care trust and $13,828 to satisfy Great-West's reimbursement claim. Great-West filed an action under Section 502(a)(3) of ERISA contending the plan's reimbursement provision required Knudson to pay $411,157 from proceeds recovered from third parties. The circuit court affirmed summary judgment in Knudson's favor, holding judicially ordered reimbursement for payments made to a beneficiary by a third party is not equitable relief authorized by Section 502(a)(3).

        Affirmed. Section 502(a)(3) authorizes a civil action to enjoin any act or practice that violates the plan, or to obtain other appropriate equitable relief. Great-West seeks to impose personal liability on Knudson for a contractual obligation of payment. A claim for money owed is not equitable relief, but rather legal relief. An injunction to compel payment under a contract or specific performance of a contract obligation is not a remedy of restitution that typically lies in equity. Because Great-West's claim of contractually entitled payment seeks legal relief, Section 502(a)(3) does not authorize this action.

—