| Montanile v. Board of Trustees of the National Elevator Industry Health Benefit Plan | |
|---|---|
 | |
| Argued November 9, 2015 Decided January 20, 2016 | |
| Full case name | Robert Montanile v. Board of Trustees of the National Elevator Industry Health Benefit Plan |
| Docket no. | 14-723 |
| Citations | 577 U.S. ___ (more) 136 S. Ct. 651; 193 L. Ed. 2d 556; 2016 U.S. LEXIS 843 |
| Case history | |
| Prior | Bd. of Trustees of the Nat'l Elevator Indus. Health Benefit Plan v. Montanile, No. 9:12-cv-80746, 2014 WL 8514011 (S.D. Fla. Mar. 17, 2014); affirmed, 593 F. App'x 903 (11th Cir. 2014); cert. granted, 135 S. Ct. 1700 (2015). |
| Holding | |
| ERISA fiduciaries cannot demand payment from a beneficiary's general assets when those assets cannot be traced back to payments from the fiduciary | |
| Court membership | |
| |
| Case opinions | |
| Majority | Thomas, joined by Roberts, Scalia, Kennedy, Breyer, Sotomayor, Kagan; Alito (except Part III–C) |
| Dissent | Ginsburg |
| Laws applied | |
| Employee Retirement Income Security Act, 29 U.S.C. § 1001 et seq. | |
Montanile v. Board of Trustees of the National Elevator Industry Health Benefit Plan, 577 U.S. ___ (2016), was a case in which the Supreme Court of the United States clarified subrogation procedures under the Employee Retirement Income Security Act ("ERISA").[1] The Court held that healthcare plan fiduciaries cannot demand reimbursement for medical benefits from a plan member's general assets if the beneficiary's general assets cannot be traced back to the original payment from the fiduciary.[2] Although some scholars suggested that the court's ruling would have little impact,[3] others suggested the case places "significant restrictions" on the rights of ERISA benefit plan providers.[4]
- ^ Montanile v. Board of Trustees of Nat. Elevator Industry Health Benefit Plan, No. 14–723, 577 U.S. ___, slip op. at 1–2 (2016).
- ^ Montanile, slip op. at 2, 8–14, 15.
- ^ See, e.g., Ronald Mann, Opinion analysis: Justices reaffirm limitations on ERISA plan’s right to recover medical-reimbursement costs, SCOTUSblog, January 20, 2016; John W. Klinker, When Equitable Remedies Give Way to Remedies at Law (or How to Avoid a Benefits Plan's Subrogation Clause), JURIST, February 24, 2016.
- ^ See, e.g., Joshua Bachrach, Montanile v. Board of Trustees: New Model for Recovery, The National Law Review, February 22, 2016.
© MMXXIII Rich X Search. We shall prevail. All rights reserved. Rich X Search