Central States, Southeast and Southwest Areas Health and Welfare Fund v. American International Group, Inc.

Federal 7th Circuit Court
Civil Court
ERISA
Citation
Case Number: 
No. 15-2237
Decision Date: 
October 24, 2016
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed

Dist. Ct. did not err in dismissing plaintiff-self-funded health plan’s action under section 502(a)(3) of ERISA seeking reimbursement from defendants-health insurance companies for medical expenses that plaintiff paid on behalf of its beneficiaries, where said beneficiaries also owned health insurance policies from said defendants. Plaintiff failed to state viable section 502(a)(3) claim, where its request for monetary relief from defendants’ general assets was legal in nature, and section 502(a)(3) allows only claims for equitable relief. Fact that basis for plaintiff’s claim is equitable in nature did not require different result, since requested relief itself must be equitable. Ct. further found that plaintiff’s request for declaration that future medical expenses of its beneficiaries must be paid by defendants was not ripe for decision. Ct. also recognized that result of case meant that plaintiff in future is left with only one way to resolve instant issue, which required that plaintiff deny payments to its members who have other insurance and then sue other insurers for declaratory judgment, which left beneficiaries in worse position even though it purchased additional health insurance.