Sixth Circuit Recognizes Benefit Planâs Equitable Lien on Overpayment By: Christopher M. Leins and Kristina F. Salamoun, Slevin & Hart, P.C., Washington, D.C. Share: A recent federal appeals court ruling provides guidance to benefit plans seeking to recover benefit overpayments made to plan participants or beneficiaries. In Zirbel v. Ford Motor Co., __ F.3d.__, 2020 U.S. App. LEXIS 36081 (6th Cir. 2020), the Sixth Circuit Court of Appeals affirmed a lower court ruling requiring a beneficiary to return $243,190 in retirement benefit overpayments made by Ford Motor Company (âFordâ). The case applies the Supreme Courtâs holding in Montanile v. Board of Trustees of the National Elevator Industry Health Benefit Plan, 577 U.S. 136 (2016), as it relates to benefit plansâ rights under ERISA to recover benefit overpayments.