EMPLOYEE RETIREMENT INCOME SECURITY ACT GOVERNED HEALTH PLANS WIN, EQUITABLE DOCTRINES LOSE: A LOOK INTO US AIRWAYS V. McCUTCHEN AND ITS IMPACT ON FUTURE ERISA LITIGATION

MATTHEW B. ANDERSEN

The Supreme Court held that, in a lawsuit brought pursuant to section 502(a)(3) of ERISA, the plain language of the plan trumps equitable doctrines when the plan’s administrator is enforcing an equitable lien, and the plan’s language is unambiguous.

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