US Airways v. McCutchen

569 U.S. 88, 133 S. Ct. 1537, 185 L. Ed. 2d 654, 81 U.S.L.W. 4236 (2013)

From our private database of 45,900+ case briefs, written and edited by humans—never with AI.

US Airways v. McCutchen

United States Supreme Court
569 U.S. 88, 133 S. Ct. 1537, 185 L. Ed. 2d 654, 81 U.S.L.W. 4236 (2013)

  • Written by Alexander Hager-DeMyer, JD

Facts

James McCutchen (defendant) was an employee of US Airways, Inc. (plaintiff) and participated in his employer’s health-benefits plan established under the Employee Retirement Income Security Act (ERISA). The plan included a reimbursement clause providing that if McCutchen was injured by a third party, the plan would cover the expenses, and McCutchen would reimburse the plan from any recovery he received from third parties, whether by lawsuit or from his own outside insurance. The plan did not address recovery costs. McCutchen was injured in a car accident and filed suit against the other driver. McCutchen received only a fraction of his medical-expenses total from the lawsuit settlement, but his lawyers secured additional funds from McCutchen’s auto insurer. McCutchen’s lawyers were contractually entitled to a 40 percent contingency fee on his total recovery. US Airways demanded reimbursement for the medical expenses it covered, and McCutchen refused. With the full recovery reduced by the attorney’s fees, McCutchen would have owed several hundred dollars to US Airways out-of-pocket to fully cover the reimbursement claim. Until the dispute could be settled, McCutchen’s attorneys placed a portion of the recovery funds in an escrow account to cover US Airways’ reimbursement amount, reduced by their allotted attorney’s fees. US Airways filed suit in federal district court for the full medical reimbursement on ERISA § 502(a)(3) grounds. The district court granted summary judgment to US Airways, and McCutchen appealed to the Third Circuit. McCutchen argued, among other things, that US Airways was required to share the litigation costs of his third-party recovery efforts. The court of appeals vacated the district court’s order, stating that the reimbursement provision was not equitable. US Airways appealed to the United States Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Kagan, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 735,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 735,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 45,900 briefs, keyed to 984 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 735,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 45,900 briefs - keyed to 984 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership