ERISA Provides Equitable Remedies to Enforce Plan Terms
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ERISA Provides Equitable Remedies to Enforce Plan Terms

Jacob Plassmeyer was injured during a collegiate baseball practice and incurred medical expenses. His college provided its student athletes insurance with First Agency (FA). Jacob's father was also insured by the Dakotas, an employee welfare benefit plan, and Jacob was covered under this Employee Retirement Income Security Act (ERISA) plan as a dependent of his father. The trustees of Dakotas brought a declaratory judgment action against FA under ERISA, seeking an order enforcing the coordination of benefits (COB) provisions in the Dakotas plan by declaring that FA's policy provided primary coverage of Jacob's claim for medical expenses already incurred. The district court denied FA's motion to dismiss and granted Dakotas' motion for summary judgment. The Eighth Circuit held that a declaratory judgment action to enforce the Dakotas plan as it applied to the claim for benefits was both consistent with the plain language of section 502(a)(3), as construed of ERISA in light of historical equitable remedies available to trustees; the court agreed with the district court that FA's coverage was primary; but the district court abused its discretion in awarding attorney fees. The court reasoned its decision “avoids the anomaly of interpreting ERISA so as to leave those Congress set out to protect—the participants in ERISA-governed plans and their beneficiaries—with less protection than they enjoyed before ERISA was enacted.”

Dakotas and Western Minnesota Electrical Industry Health and Welfare Fund, First Agency, Inc.