QualChoice, Inc. v. Rowland’s Empirical Analysis
367 F.3d 638 · 2004
Citation profile
13 federal appellate · 2 district · 4 state decisions
Appellate journey
Relationships
Applies 28 U.S.C. § 1331 · 29 U.S.C. § 1132 (§ 502 of the Employee Retirement Income Security Act of 1974)
Relies on Massachusetts Mutual Life Insurance v. Russell · Mertens v. Hewitt Associates · Great-West Life & Annuity Insurance v. Knudson · Melka Marine, Inc. v. United States · Brickwood Contractors, Inc. v. United States
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the source of the claim asserted by [the ERISA plan] is a contract to pay money, and ... the procedural mechanisms of constructive trust and equitable lien are not proper mechanisms for enforcing this right, as such relief would not have traditionally been awarded by a court of equity in a breach of contract action. ... [A] plan fiduciary’s action to enforce a plan-reimbursement provision is a legal action, regardless of whether the plan participant or beneficiary recovered from another entity and possesses that recovery in an identifiable fund.”
2 later decisions quote this exact passage · from the majority“did hot, in its complaint, allege that it had given certain funds to [the participant], trace those funds to the settlement funds from [the tortfeasor], allege that [the participant] was unjustly enriched by retaining the settlement funds, and seek the return of the settlement funds in [the participant’s possession]. Rather, [the fiduciary] sought “restitution from [the participant] for all covered services”.”
1 later decision quote this exact passage · from the majority“[t]he fact that a plan participant or beneficiary places the money he recovered from another in a bank account does not, however, change the nature of the action. The plan may have obligated Rowland to reimburse QualChoice in the event that QualChoice paid for Rowland’s medical expenses, but it did not give QualChoice a property right in any particular fund.”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.