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

In Great-West Life & Annuity Insurance Co. v. Knudson (2002) 534 U.S. 204, the question addressed by the United States Supreme Court was whether an employee benefit plan was authorized under the Employee Retirement Income Security Act (ERISA) to bring an action in federal court for specific performance of the reimbursement provision of the plan, and thereby compel a plan beneficiary who had received a personal injury settlement to reimburse the plan for the medical expenses paid by the plan. (Knudson, supra, 534 U.S. at pp. 206-207.) The Supreme Court concluded that because the plan was seeking legal relief ("the imposition of personal liability on respondents for a contractual obligation to pay money)," rather than equitable relief, the plan's federal action was not authorized under ERISA. (Id. at p. 221.)