Montanile v. Board of Trustees of the National Elevator Industry Health Benefit Plan

136 S.Ct. 651 (2016)

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Montanile v. Board of Trustees of the National Elevator Industry Health Benefit Plan

United States Supreme Court
136 S.Ct. 651 (2016)

  • Written by Rose VanHofwegen, JD

Facts

Robert Montanile (defendant) suffered injuries in a car accident with a drunk driver. His employer’s Employee Retirement Income Security Act (ERISA) plan paid over $121,000 for his medical care, subject to reimbursement if Montanile recovered from a third party. Montanile signed an agreement reaffirming that reimbursement obligation. Montanile sued the drunk driver and obtained a $500,000 insurance settlement. After attorney fees and advances, $240,000 remained in his attorney’s trust account. Plan administrator Board of Trustees of the National Elevator Industry Health Benefit Plan (the board) (plaintiff) sought reimbursement, but Montanile’s attorney disputed its entitlement. Negotiations failed, and Montanile’s attorney said he would release the funds to Montanile unless the board objected within 14 days. The board failed to do so, and Montanile’s attorney released the funds. Six months later, the board sued for reimbursement, seeking an equitable lien on the settlement funds or any other property in Montanile’s possession. The district court granted the board summary judgment, and the Eleventh Circuit affirmed. Montanile petitioned the Supreme Court for review.

Rule of Law

Issue

Holding and Reasoning (Thomas, J.)

Dissent (Ginsburg, J.)

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