Mealey's (January 25, 2016, 11:55 AM EST) -- WASHINGTON, D.C. — The U.S. Supreme Court in a summary disposition on Jan. 25 vacated the 11th Circuit U.S. Court of Appeals’ divided opinion that a welfare benefits plan was entitled to reimbursement of medical costs it spent on behalf of a plan participant because the plan created an equitable lien by agreement and strict tracing rules did not apply, and the Supreme Court remanded for further consideration in light of its Jan. 20 ruling in Montanile v. Board of Trustees of Nat. Elevator Industry Health Benefit Plan (Brenda Elem v. AirTran Airways, Inc., No. 14-1061, U.S.)....