The 3rd U.S. Circuit Court of Appeals has ruled that subrogation claims in ERISA cases can be limited by equitable defenses and principles such as unjust enrichment.

A unanimous three-judge 3rd Circuit panel vacated a ruling by the U.S. District Court for the Western District of Pennsylvania, finding that under the Employee Retirement Income Security Act of 1974, subrogation claims may be subject to certain equitable limitations at courts’ discretion.