Pyle v. Beverly Enterprises-Texas, Inc.
Hollye Pyle sued her employer, Beverly Enterprises-Texas, Inc. (Beverly), for negligence, intentional infliction of emotional distress, and breach of duty of good faith and fair dealing following a workplace injury. Beverly, a nonsubscribing employer under the Texas Workers’ Compensation Act, operated an ERISA-governed employee benefit plan that required employees to sign a waiver to receive benefits. Beverly removed the case to federal court, asserting ERISA preemption. The court denied Pyle's motion to remand, distinguishing between the claims. It held that while the negligence claim was not preempted, the intentional infliction of emotional distress and breach of duty of good faith and fair dealing claims directly related to the ERISA plan's administration and were therefore preempted. The court further indicated its intent to potentially grant summary judgment on the preempted claims and remand the remaining negligence claim to state court.