"Affirmance of the Eleventh Circuit's decision would represent a practical solution to a common problem faced by fiduciaries who attempt to recover from non-fiduciary plan participants or service providers asserting a right to plan benefits based on assignment.... Should the Supreme Court reverse, non-fiduciary recipients of plan funds would be provided with a perverse incentive to spend plan money immediately upon receipt so as to avoid any repayment obligations set forth by plan terms." [Bd. of Trustees of the National Elevator Industry Health Benefit Plan v. Montanile, No. 14-11678 (11th Cir. Nov. 25, 2014; cert. pet. granted Mar. 30, 2015)]