MBI Energy Services v. Hoch, No. 18-1539 (8th Cir. 2019)Annotate this Case
The Eighth Circuit affirmed the district court's grant of summary judgment to MBI in an action brought by MBI seeking reimbursement of the benefits it paid to defendant under a self-funded employee benefit plan sponsored and administered by MBI. The court held that the Employee Retirement Income Security Act allows a fiduciary such as MBI to bring an action for equitable relief to enforce the terms of an employee benefit plan.
The court also held that MBI was entitled to reimbursement because the Summary Plan Description was the plan's written instrument and defendant did not dispute that its reimbursement provision required him to pay MBI if it was an enforceable part of the plan. The court rejected defendant's remaining claims.