Sereboff v. Mid-Atlantic Medical Services, Inc., 547 U.S. 356 (2006)

In Sereboff v. Mid-Atlantic Medical Services, Inc., 547 U.S. 356 (2006), an ERISA Plan sued the plan beneficiaries when funds were distributed to the Sereboffs without first satisfying an ERISA lien. The ERISA plan sued for injunctive relief, requesting a temporary restraining order and preliminary injunction requiring the couple to retain and set aside at least $74,869.37 from the settlement proceeds to reimburse the plan for medical benefits. The district court approved a stipulation by the parties where the Sereboffs agreed to preserve $74,869.37 in an investment account until the issue was resolved. The Court held that the Plan could bring an equitable claim under § 502(a)(3)(B) of the ERISA Act. It then found that enforcement of an agreement to pay money upon receipt is an equitable action and that the agreement constitutes a lien. The Court distinguished the result here from Knudson because the plan sought specific funds, subject to the agreement, which were still in the hands of the Sereboffs.