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Federal Courts -
U. S. Supreme Court - January 8 - January 9, 2002
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Great-West Life & Annuity Ins. Co. v. Knudson, No. 99-1786,
SUPREME COURT OF THE UNITED STATES, January 8, 2002, Decided
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Overview: The insurance companies had paid one beneficiary's medical expenses pursuant to a stop-loss insurance agreement with an ERISA benefit plan. After the beneficiaries received a settlement from a car manufacturer in a state court action, the insurance companies sought to enforce the ERISA plan's reimbursement provision under. The insurance companies were not entitled to relief underbecause the relief they sought was not equitable in nature. Rather, it was a claim for money damages. The court rejected the insurance companies' arguments that they sought to enjoin an act or practice because an injunction to compel the payment of money was not typically available in equity. Moreover, the fact that the insurance companies had sought restitution did not make the claim for relief an equitable one because the kind of restitution they sought, personal liability for the benefits they had conferred on the beneficiaries, was a legal remedy. Likewise, the court rejected the argument that the common law of trusts provided the insurance companies with equitable remedies because that form of relief was not typically available in equity.
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Toyota Motor Mfg., Ky. v. Williams, No. 00-1089,
SUPREME COURT OF THE UNITED STATES, January 8, 2002, Decided
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Overview: The appellate court had determined that the employee was disabled under the ADA when she sought an accommodation from her former employer. The appellate court had not applied the proper standard in making that determination because it analyzed only a limited class of manual tasks, i.e., those tasks the employee performed on an engine fabrication assembly line. Moreover, the appellate court failed to ask whether the employee's impairments prevented or restricted her from performing tasks that were of central importance to most people's daily lives, such as tending to personal hygiene and carrying out personal or household chores. The Court concluded that to be substantially limited in performing manual tasks under the ADA, an individual was required to have an impairment that prevented or severely restricted the individual from doing activities that were of central importance to most people's daily lives and the impairment's impacts were required to be permanent or long-term. The Court declined to reinstate the trial court's grant of summary judgment on the manual task issue because the employer had not sought summary judgment in its petition for certiorari.
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