Great-West Life & Annuity Insurance Co. v. Knudson — Ginsburg, J., Dissenting

Summary

Justice Ginsburg dissents, arguing the majority's interpretation of ERISA § 502(a)(3) revives obsolete law-equity distinctions that frustrate statutory purpose. She views restitution as traditionally equitable relief available in modern courts. Justice Stevens joined the dissent and separately argued § 502(a)(3)(A) permits injunctive relief without historical analysis.