Supreme Court Decides McCuthen

In a 5-4 decision, the Supreme Court holds that a well-drafted reimbursement provision of a plan will prevail against equitable claims.

Document Excerpt

In a §502(a)(3) action based on an equitable lien by agreement— like this one—the ERISA plan’s terms govern. Neither general unjust enrichment principles nor specific doctrines reflecting those principles—such as the double-recovery or common-fund rules invoked by McCutchen—can override the applicable contract.

 

Link http://www.supremecourt.gov/opinions/12pdf/11-1285_i4dk.pdf

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