ERISA-Seventh Circuit Says That A Plan’s Suit Involving A Coordination Of Benefits Dispute Seeks Legal Relief, Note Equitable Relief, And Therefore Cannot Be Brought Under Section 502(a)(3) of ERISA

In Central States, Southeast and Southwest Areas Health and Welfare Fund v. American International Group, Inc., No. 15-2237 (7th Cir. 2016), a self-funded ERISA plan had sued several independent health insurers seeking reimbursement for medical expenses it paid on behalf of beneficiaries who were covered under both the plan and the insurers’ policies. The Seventh Circuit Court of Appeals (the “Court”) was asked to decide whether a lawsuit like this one—a “coordination of benefits” dispute—seeks “appropriate equitable relief” under section 502(a)(3) of ERISA. Six circuits have held that section 502(a)(3) does not authorize suits of this type because the relief sought is legal, not equitable. The Court decided to join this consensus and affirm the dismissal of the ERISA plan’s suit.

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