ERISA Plan Reimbursement Limited by Equitable Principles: Third Circuit

The US Court of Appeals for the Third Circuit held that, under ERISA Section 502(a)(3), an employee benefit plan was not entitled to full reimbursement for medical expenses it incurred on behalf of a participant and was limited by equitable principles and defenses to “appropriate” relief, despite plan language specifying full reimbursement. In its decision in US Airways v. McCutchen, the court held that the plan could not recover the full cost of the participant’s medical expenses when the participant recovered less from a third party.

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