In Quest Diagnostics v. Bomani, et al., 11-CV-00951 (D. Conn., June 19, 2013), the court granted Quest Diagnostic’s (“Quest”) motion for summary judgment, ruling that Quest, as the fiduciary to its self-insured medical plan, could recover medical benefits paid to its employee after the employee was injured in an accident and recovered a
Equitable Relief
U.S. Supreme Court Rules That Plan Terms Trump Equitable Defenses
By Myron Rumeld & Russell Hirschhorn on
Today, the U.S. Supreme Court issued its ruling in U.S. Airways, Inc. v. McCutchen in which the Court unanimously ruled that a clearly drafted reimbursement clause will trump all equitable defenses. The Supreme Court’s ruling will likely be viewed favorably by plan sponsors, as it will allow them to anticipate with more certainty the impact…
Second Circuit: Deferential Standard Applies Without Notice To Participants & Reimbursement Claims Are Equitable Relief
By Russell Hirschhorn on
Yesterday, the Second Circuit ruled on two important issues of note for ERISA plan sponsors and plan fiduciaries.
In Thurber v. Aetna Life Insurance Co., 2013 WL 950704 (2d Cir. Mar. 13, 2013), the Court ruled that participants and beneficiaries are not required to be put on notice that:
- the plan fiduciary has reserved
…