Third Circuit -- ACS Recovery Services, Inc., et al v. Larry Griffi

ERISA --

Claim for relief under the statute suffices for jurisdiction irrespective of final decision on merits.

Constructive trust can be imposed as equitable relief against Participant's trust which received commingled funds from a tort recovery, since the Administrator had a right to recover earlier payments.

Concur/dissent -- recovery from individuals, not the trust.

Concur/dissent -- Commingled funds in special needs trust are unreachable.

ACS Recovery Services, Inc., et al v. Larry Griffi