Montanile v. Board of Trustees of National Elevator Industry Health Benefit Plan
The Conclusion
**The Supreme Court held that ERISA plans cannot pursue equitable liens when settlement funds are wholly dissipated on nontraceable items.** Because the res no longer exists, equitable relief is unavailable.
No circuit court data for this case.
Case Analysis
Overview
Continued narrowing equitable relief under ERISA, holding that when a participant wholly dissipates settlement funds on nontraceable items, the plan cannot pursue an equitable lien because the specific res no longer exists.
Conclusion
**The Supreme Court held that ERISA plans cannot pursue equitable liens when settlement funds are wholly dissipated on nontraceable items.** Because the res no longer exists, equitable relief is unavailable.
Notes
Extends Great-West's strict historical-equity requirement. Dissipated funds = no equitable remedy. Thomas wrote the majority.
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