Cent. States, SE & SW Areas Health & Welfare Fund v. Student Assurance Servs., Inc., No. 14-2376 (8th Cir. 2015)
Annotate this CaseCentral States, a multi-employer trust fund governed by ERISA, provides health and welfare benefits to participants in the teamster industry. Student Assurance processed claims for student accident policies. Central States claimed that it paid medical expenses of $137, 204 for 13 junior high, high school, and college student-athletes who were covered dependents under its plan and who sustained athletic injuries. Central States sought reimbursement from Student Assurance, which refused to pay. Central States alleged that according to the coordination of benefits provision of its plan, the student accident policies supply primary coverage for the students’ covered medical expenses. Student Assurance claimed that the student accident policies are excess policies, and that they are not obligated to pay until Central States has reached the maximum contribution under its plan. Central States sued, citing federal common law and section 502(a)(3) of ERISA, seeking declaratory relief, restitution, and the imposition of an equitable lien and constructive trust to secure reimbursement for the benefits paid on behalf of the common insureds. The district court dismissed, and the Eighth Circuit affirmed, holding that the claims, while ostensibly seeking equitable remedies, were actually for legal relief that is unavailable under section 502(a)(3).
Court Description: Colloton, Author, with Wollman and Beam, Circuit Judges] Civil case - ERISA. The court joins with other circuits in holding that Central States' claims against insurance providers not governed by ERISA for restitution and the imposition of an equitable lien and constructive trust to secure reimbursement for benefits Central States paid on behalf of common insureds are claims for legal, rather than equitable, remedies and are barred by Great-West Life & Annunity Inc. Co. v. Knudson, 534 U.S. 204 (2002).
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