Great-West Life & Annuity Insurance Co. v. Knudson

Summary

Justice Scalia, writing for five Justices, held that ERISA § 502(a)(3) did not authorize the plan's reimbursement action because it sought personal liability for a contractual obligation to pay money, rather than relief typically available in equity. Labeling the requested relief an injunction or restitution did not change its legal character; the settlement funds were held by a special needs trust and counsel, not by the beneficiaries. The Court affirmed the Ninth Circuit. Justice Stevens dissented separately and also joined Justice Ginsburg's dissent. He would read the statutory authorization to enjoin plan violations independently of historical restrictions on equitable relief. Justice Ginsburg, joined by Justices Stevens, Souter, and Breyer, argued that restitution was a category of relief typically available in equity and that the majority's historical distinctions frustrated ERISA's purposes.