6th Circuit Court of Appeals; Docket No. 01-4095; Published
Judges Siler, Rogers, and Gwin; unanimous
Official Reporter Citation: Forthcoming, Link to Opinion 
STATUTORY INDEXING:
Not applicable
TOPICAL INDEXING:
Employee Retirement Income Security Act (ERISA – 29 USC Section 1001 Et Seq.)
Federal Jurisdiction and Removal of PIP Claims
CASE SUMMARY:
In this unanimous published opinion, the United States Court of Appeals, 6th Circuit, held that the district court lacked subject matter jurisdiction over a claim in which the Community Health Plan of Ohio filed a breach of contract claim against its beneficiary, Mosser, requesting restitution for medical payments it had made on behalf of Mosser for treatment of injuries arising from a motor vehicle accident.
The Court of Appeals held that the Employee Retirement Income Security Act (ERISA) does not authorize actions brought by ERISA plan fiduciaries against plan beneficiaries to enforce plan reimbursement provisions through money damages. The court held that the recent Supreme Court decision, Great-West Life & Annuity Insurance Company v Knudson, 534 US 204, 122 S Ct 708, 151 L Ed2d 635 (2002) held that when a fiduciary seeks to impose personal liability on a plan beneficiary for a contractual obligation to pay money, the action is an action at law, not an action in equity. Since 29 USC §1132(a)(3) only authorizes actions seeking equitable relief, ERISA does not provide jurisdiction for fiduciaries seeking to enforce a contract’s reimbursement provisions through money damages. Therefore, the matter was remanded with instructions to the United States District Court to dismiss this matter for lack of jurisdiction.