US Airways, Inc., in Its Capacity As Fiduciary and Plan Administrator of the US Airways, Inc. Employee Benefits Plan, Petitioner v. James E. Mccutchen et al. (569 U.S. 88)
U.S. Supreme Court · decided April 16, 2013 · Supreme Court Database (Spaeth)
- Citation
- 569 U.S. 88 · 133 S. Ct. 1537
- Decided
- April 16, 2013
- Term
- October Term 2012
- Vote
- 5–4
- Majority author
- Justice Kagan
- Issue area
- Economic Activity
- Disposition
- Vacated and remanded
- Outcome
- Petitioning party lost
- Ideological direction
- Conservative
Opinion excerpt
Justice KAGAN delivered the opinion of the Court. Respondent James McCutchen participated in a health benefits plan that his employer, petitioner U.S. Airways, established under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. § 1001 et seq. That plan obliged U.S. Airways to pay any medical expenses McCutchen incurred as a result of a third party's actions-for example, another person's negligent driving. The plan in turn entitled U.S. Airways to reimbursement if McCutchen later recovered money from the third party. This Court has held that a health-plan administrator like U.S. Airways may enforce such a reimbursement provision by filing suit under § 502(a)(3) of ERISA, 88 Stat. 891, 29 U.S.C. § 1132(a)(3). See Sereboff v. Mid Atlantic Medical Services, Inc., 547 U.S. 356, 126 S.Ct. 1869, 164 L.Ed.2d 612 (2006). That section authorizes a civil action "to obtain ... appropriate equitable relief ... to enforce ... the terms of the plan." We here consider whether in that kind of suit, a plan participant like McCutchen may raise certain equitable defenses deriving from principles of unjust enrichment. In particular, we address one equitable doctrine limiting reimbursement to the amount of an insured's "double recovery" and another requiring the party seeking reimbursement to pay a share of the attorney's fees incurred in securing funds from the third party.…
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