"[T]he Court affirmed that equitable theories, such as make-whole, common fund, unjust enrichment and double-recovery doctrines should not be allowed to override a plan's clear language reserving its right to full reimbursement for benefits it paid when all other contractual conditions are met. The reason cited by the High Court in its 5-4 decision is that the plan's reimbursement agreement is mutual, whereas after-the-fact carve-outs to protect a plan participant from equitable defenses such as windfall, unjust enrichment, etc., are unilateral."  MORE >>