CHWT

In this opinion, we consider whether the federal Employee Retirement Income Security Act of 1974 (ERISA) ( 29 U.S.C. §1001 et seq.) preempts a common law cause of action by an ERISA fiduciary against an ERISA plan beneficiary for breach of an agreement settling an earlier federal court lawsuit concerning the reimbursement of medical benefits paid by the fiduciary. We conclude that it does not.

I. Facts

Carpenters Health and Welfare Trust Fund for California (CHWT) is an “employee benefit trust fund established pursuant to an agreement and declaration of trust executed by employer associations representing employers in the unionized construction industry and union representatives affiliated with the United Brotherhood of Carpenters and Joiners of America.” CHWT is governed by a board of trustees (Trustees), which established the CHWT health and welfare plan (Plan). The Plan provides medical, hospitalization and other benefits to “covered participants and their eligible dependents,” but “requires reimbursement . . . when a participant or eligible dependent recovers from a potentially liable third party.”

Rodney McCracken is a carpenter eligible for benefits under the…