2001 Supreme Court term

GREAT-WEST LIFE & ANNUITY INSURANCE COMPANY, ET AL. v. JANETTE KNUDSON, ET VIR.

Dockets 99-1786Argued
AI-generated independent summary

This educational guide is based on the linked primary sources. It is not a Court publication, is not affiliated with the Court, and is not legal advice.

In brief

Overview

According to Petitioners (Great-West Life & Annuity Insurance Company), great‑West Life & Annuity Insurance Company (the petitioners) seek injunctive and declaratory relief to enforce a reimbursement clause in the employee benefit plan.

According to Petitioners (Great-West Life & Annuity Insurance Company), the petitioners argue that ERISA §502(a)(3)(A) authorizes a civil action to enjoin any act that violates the terms of the plan, supporting their request for an injunction against the respondents.

According to Petitioners (Great-West Life & Annuity Insurance Company), section 404(a) of ERISA obligates fiduciaries to enforce the terms of the plan, reinforcing the petitioners’ claim.

According to United States, an amicus curiae brief filed on behalf of the United States supports the petitioners’ position that the plan’s enforcement mechanism is the only way to protect its terms.

Background and question before the Court

According to Justice Scalia, the central legal question is whether an equitable remedy, such as an injunction, is available under ERISA when the federal statute provides no explicit legal remedy.

According to Justice Scalia, a related question is whether the phrase “enjoin any act” in §502(a)(3)(A) includes a failure to act.

According to Questioner, another issue raised is the oddity that a body of federal common law would be applied only in state courts.

What each side argues

Petitioners

According to Petitioners (Great-West Life & Annuity Insurance Company), the petitioners contend that ERISA §502(a)(3)(A) provides a clear basis for an injunction to stop the respondents from disbursing funds contrary to the plan.

According to Petitioners (Great-West Life & Annuity Insurance Company), they argue that the language, structure, and purpose of ERISA support enjoining the respondents from disbursing funds they have power to determine.

According to Petitioners (Great-West Life & Annuity Insurance Company), they invoke the concept of a constructive trust, as used by lower courts, to enforce reimbursement obligations.

According to Petitioners (Great-West Life & Annuity Insurance Company), section 404(a) of ERISA obligates fiduciaries to enforce the terms of the plan, reinforcing their claim.

Respondents

Source-limited. The record does not yet support a complete account.

What happened at oral argument

Justice Scalia asked whether, because the federal statute provides no legal remedy, an equitable remedy is available under ERISA.

According to Justice Scalia, he further queried whether the phrase “enjoin any act” includes a failure to act.

According to Questioner, a questioner noted the oddity that a body of federal common law would be applied only in state courts.

Mr. Taranto argued that state tort law creates a negligence claim and that subrogation should follow the terms of the ERISA plan, allowing the plan to step into the beneficiary’s shoes.

According to Mr. Taranto, he contended that the preemption argument against the subrogation suit is weak and does not require a strong response.

According to Mr. Taranto, he referenced legislative history indicating that earlier drafts of the provision allowed broader legal or equitable relief, which was later narrowed.

What the Court decided

Pending This section will be added when the relevant Court material is available.

Why it matters

Source-limited The available primary sources do not support a complete explanation yet.

Terms to know

No glossary terms are available for this guide.

Primary sources

Read the source materials on the official site or open the immutable repository copy used for this guide.

  • 78635232be688e6e4434-r1-1d58406068da091f.pdforal argument transcript

Guide generated September 19, 2026. Automated validation accepted this version.