State of Connecticut v. Physicians Health Services of Connecticut, Inc.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that a plaintiff who was not a participant, beneficiary, or fiduciary of a benefit plan lacked standing to seek equitable relief pursuant to 29 U.S.C. § 1132(a)(3)
• holding that a provision “limit[ing] states’ power to sue as parens patriae . . . does not commandeer any branch of state government because it imposes no affirmative duty of any kind on them”
• noting that Section 502 “allows ‘a participant, beneficiary, or fiduciary’ of an ERISA-regulated plan to bring a civil action for injunctive and other equitable relief”
• noting that Section 502 “allows ‘a participant, beneficiary, or fiduciary’ of an ERISA-regulated plan to bring a civil action for injunctive and other equitable relief”
• requiring that the “remedies being sought . . . flow to the [named plaintiff] as assignee,” but not addressing how the assignee has contracted to dispose of those remedies after the lawsuit
• noting that “[a]bsent a valid assignment of a claim, ... nonenumerated parties lack statutory standing to bring suit under [ERISA] even if they have a direct stake in the outcome of the litigation”

Source: CourtListener parenthetical corpus (CC0).