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

No. 14-723 SCOTUS · Decided Decided SCOTUS


The Conclusion

**The Supreme Court held that ERISA plans cannot pursue equitable liens when settlement funds are wholly dissipated on nontraceable items.** Because the res no longer exists, equitable relief is unavailable.

CourtSupreme Court of the United States
FiledDec 19, 2014
CL StatusActive
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No circuit court data for this case.

Cert Granted -
StatusActive
Filed (CL)Dec 19, 2014
View on CourtListener →
SCOTUS TMR-b235ff20 Jun 14, 2026

Case Analysis

Overview

Continued narrowing equitable relief under ERISA, holding that when a participant wholly dissipates settlement funds on nontraceable items, the plan cannot pursue an equitable lien because the specific res no longer exists.

Conclusion

**The Supreme Court held that ERISA plans cannot pursue equitable liens when settlement funds are wholly dissipated on nontraceable items.** Because the res no longer exists, equitable relief is unavailable.

Notes

Extends Great-West's strict historical-equity requirement. Dissipated funds = no equitable remedy. Thomas wrote the majority.

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