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Great-West Life & Annuity Insurance Co. v. Knudson

No. 99-1786 SCOTUS · Decided Decided SCOTUS


The Conclusion

The Supreme Court held that equitable relief under ERISA 502(a)(3) is limited to remedies with strict historical analogues in equity. Only remedies traditionally available in equity (not at law) qualify, excluding modern equitable relief developed after the founding of equity jurisprudence.

CourtSupreme Court of the United States
FiledJan 8, 2002
CL StatusActive
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Cert Granted -
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SCOTUS TMR-eb55fe6f Jun 14, 2026

Case Analysis

Overview

Narrowed the scope of equitable relief available under ERISA 502(a)(3) by requiring strict historical analogues. Only relief that was typically available in equity (not at law) qualifies, limiting modern equitable remedies.

Conclusion

**The Supreme Court held that equitable relief under ERISA 502(a)(3) is limited to remedies with strict historical analogues in equity.** Only remedies traditionally available in equity, not at law, qualify, excluding modern equitable relief developed after the founding of equity jurisprudence.

Notes

Part of the ERISA equity trilogy (with Montanile and Sereboff). Applied strict historical-equity test to limit available remedies.

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