577 U.S. 136 (2016), U.S. Supreme Court
Montanile v. Board of Trustees is a cornerstone ERISA case clarifying the limits of equitable relief available to plan fiduciaries under § 502(a)(3).
Under ERISA § 502(a)(3), may a plan fiduciary enforce a reimbursement provision by obtaining equitable relief against a participant's general assets after the participant has dissipated specifically identifiable settlement funds on nontraceable expenses?
Section 502(a)(3) authorizes only appropriate equitable relief. A plan fiduciary may enforce an equitable lien by agreement or other equitable remedy only against specifically identifiable funds or property in the defendant's possession. If the specific fund to which the lien attached has been dissipated on nontraceable items, equity does not permit recovery from the defendant's general assets under § 502(a)(3).
No. When a participant dissipates the specifically identifiable settlement funds on nontraceable items, an ERISA fiduciary cannot enforce a reimbursement provision against the participant's general assets under § 502(a)(3). The Supreme Court reversed and remanded.
Montanile cements the tracing requirement for ERISA § 502(a)(3) reimbursement claims. It teaches that plan language alone does not guarantee recovery; fiduciaries must locate and identify the specific fund or traceable property still in the participant's hands. Practically, the case pushes plans to act swiftly—seeking TROs, preliminary injunctions, and segregation orders—to prevent dissipation. Doctrinally, it harmonizes Great-West, Sereboff, and McCutchen: ERISA authorizes only equitable relief; equitable liens by agreement are enforceable against identifiable funds; plan terms control the parties' substantive rights but cannot transform a barred legal remedy into an authorized equitable one. For students, Montanile is a prime example of statutory interpretation through the lens of historical equity and of how remedial law shapes litigation outcomes.