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ERISA Update: Positive News from SCOTUS in Montanile

• Blog
• January 19th, 2016

The Supreme Court of the United States issued its opinion today in Montanile v. Board of Trustees of the National Elevator Industry Health Benefit Plan, 577 U.S. ___ (2016).  This ERISA reimbursement case was decided on the issue of whether or not dissipation of settlement funds by the plan participant defeated a plan's claim for equitable relief under §502(a)(3).  In an eight-to-one decision by the Supreme Court, Justice Thomas held that when a plan participant dissipates settlement funds on non-traceable assets, which would otherwise be subject to an equitable lien by agreement, the plan is not permitted to assert a claim against the participant's general assets.

This case resolved a split among the Circuits, which were in disagreement over whether an equitable lien by agreement could be enforced when the person has dissipated the fund to which the lien attached.