Honolulu Joint Apprenticeship & Training Committee of United Ass'n Local Union No. 675 v. Foster

**What Happened:** Foster was an apprentice in a plumbing training program run by the Honolulu Joint Apprenticeship & Training Committee and a local union. When Foster left the program, the training committee sued him to recover the money they had spent on his training. They claimed he had broken his contract by not completing the program and should pay back the training costs. **What the Court Decided:** The court ruled in favor of Foster, finding that he did not have to repay the training costs. The court determined that the training committee was asking for "legal restitution" (getting money back), but under ERISA (a federal law governing employee benefit plans), they could only seek "equitable relief" (non-monetary remedies). Since money damages weren't allowed under the specific ERISA provision the committee used, their lawsuit failed. However, Foster was not awarded attorney's fees. **Why This Matters for Workers:** This ruling protects workers from being forced to repay training costs when they leave apprenticeship or training programs early. It shows that employers and training organizations cannot always use ERISA to recover their training investments from departing workers, giving employees more freedom to change career paths without financial penalties.