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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Empire Blue Cross & Blue Shield v. Consolidated Welfare Fund

Empire Blue Cross and Blue Shield (Empire) sued the Consolidated Welfare Fund and other defendants for breach of contract, fraud, and RICO violations. The defendants moved for partial judgment on the pleadings, asserting that the state law claims were preempted by ERISA. The court analyzed whether the Fund qualified as an 'employee welfare benefit plan' (EWBP) under ERISA. Finding that the Fund, with its 'associate members' from diverse backgrounds and commercial solicitation, did not meet the criteria of an EWBP, the court concluded that ERISA preemption did not apply. Therefore, the defendants' motion for partial judgment on the pleadings was denied, allowing Empire's state law claims to proceed.

ERISA PreemptionEmployee Welfare Benefit PlanHealth Insurance FraudLabor Union MembershipAssociate MembersRule 12(c) MotionFederal Civil ProcedureStatutory InterpretationCommercial Insurance SchemesDistrict Court Ruling
References
11
Case No. MISSING
Regular Panel Decision
Sep 30, 2003

In Re Enron Corp. Securities, Derivative & ERISA

This case, referred to as the 'Tittle action,' involves class action claims brought by Enron employees who participated in three pension benefit plans (Savings Plan, ESOP, and Cash Balance Plan). Plaintiffs allege breaches of fiduciary and co-fiduciary duties under ERISA, RICO violations, and Texas common law claims (negligent misrepresentation and civil conspiracy) against Enron, its officers, directors, administrative committees, Arthur Andersen, Vinson & Elkins, and several investment banks. The court grants motions to dismiss for most RICO and common law claims, citing preemption by the Private Securities Litigation Reform Act (PSLRA) and the Securities Litigation Uniform Standards Act (SLUSA), as the underlying conduct is actionable as securities fraud. However, the court largely denies motions to dismiss for the ERISA claims, allowing them to proceed, finding that plaintiffs have adequately stated claims for breach of fiduciary duty related to imprudent investments in Enron stock, plan lockdowns, and failure to diversify plan assets. The decision outlines the various duties and liabilities of fiduciaries, co-fiduciaries, and non-fiduciaries under ERISA.

ERISAFiduciary DutyCo-Fiduciary LiabilityDirected TrusteeSecurities Litigation Reform ActSLUSA PreemptionClass ActionPension PlansESOP401(k) Plan
References
247
Case No. MISSING
Regular Panel Decision

Romney v. Lin

This opinion addresses an action to collect unpaid contributions owed by Goodee Fashions, Inc. to four union benefit funds, totaling $70,647.17. After an initial judgment against Goodee Fashions proved uncollectible, the plaintiff, representing the union benefit funds, sued Alan Lin, a principal shareholder, under New York Bus. Corp. Law § 630. This state law holds the ten largest shareholders jointly and severally liable for debts to employees, including benefit funds. Defendant removed the case to federal court, arguing preemption by ERISA and LMRA. The court denied the plaintiff's motion to remand and granted the defendant's motion to dismiss, ruling that N.Y. Bus. Corp. Law § 630 is preempted by ERISA. Consequently, the claim for $70,647.17 was dismissed, except for a $598.27 portion related to the Sportswear Industry Trust Fund, which was deemed not an ERISA fund.

ERISA PreemptionLMRAShareholder LiabilityUnpaid ContributionsEmployee Benefit PlansCollective BargainingState Law PreemptionFederal JurisdictionCorporate DebtDismissal
References
11
Case No. 08-2192
Regular Panel Decision
Mar 09, 2010

In Re Regions Morgan Keegan Erisa Litigation

Plaintiffs, current or former employee participants in Regions sponsored 401(k) retirement plans, filed a class action lawsuit under the Employee Retirement Income Security Act of 1974 (ERISA) against various fiduciaries and parties in interest, including Regions Financial Corporation, Regions Bank, Morgan Keegan & Company, Inc., and Morgan Asset Management, Inc. The Complaint alleged that the Plans suffered losses due to imprudent investments in Regions' company stock, high-risk Bond Funds, and excessive fees charged by RMK Select Funds, facilitated by self-dealing and revenue sharing. Defendants filed motions to dismiss, asserting various defenses including exemptions under ERISA, lack of fiduciary status for some individuals, and the applicability of ERISA § 404(c). The court largely denied the motions to dismiss, finding that Plaintiffs had sufficiently pled facts for most claims to proceed, but granted the motion to dismiss Count V against Morgan Keegan and MAM.

ERISA401(k) PlanFiduciary DutyMotion to DismissClass ActionInvestment ManagementExcessive FeesProhibited TransactionCompany StockBond Funds
References
42
Case No. MISSING
Regular Panel Decision

State of Tex. v. NATIONAL COUNCIL OF ALLIED EMP.

This case addresses a petition for removal filed by various defendants, seeking to transfer a state lawsuit to federal court on the grounds of ERISA preemption. District Judge NOWLIN presided over an evidentiary hearing to determine the applicability of ERISA's preemption provisions to the State's claims. The Court examined whether the defendant entities qualified as ERISA plans and if the subscribers were considered 'employees' who 'participated' in these organizations under ERISA's definitions. Ultimately, the Court found that the defendants failed to meet their burden to demonstrate that the plans were subject to ERISA preemption. Therefore, the petition for removal was denied, and the cause was remanded to the state court.

ERISA PreemptionFederal Court RemovalState Law ClaimsEmployee Benefit Plan RegulationSelf-Funded PlansDeemer ClauseDefinition of EmployeeMultiemployer Welfare ArrangementsTexas Workers' CompensationFederal Jurisdiction
References
16
Case No. MISSING
Regular Panel Decision
Dec 27, 2001

MacRo v. Independent Health Ass'n, Inc.

Plaintiffs Cheryl Macro and Kim Zastrow, insured under a group health contract with Independent Health through the Tonawanda City School District, initiated a class action in state court to challenge Independent Health's modification of infertility treatment coverage. Defendant Independent Health removed the case to federal court, asserting ERISA preemption. Plaintiffs moved to remand, arguing that their claims fell under New York Insurance Law, which is exempt from ERISA preemption by the saving clause, and that their health plan qualified as a 'governmental plan' also exempt from ERISA. The District Court granted the plaintiffs' motion, concluding that the claims were indeed saved from ERISA preemption and that the plan was exempt, thus rendering federal subject matter jurisdiction absent. The court accordingly remanded the case back to New York State Supreme Court.

Infertility CoverageHealth Insurance DisputesERISA PreemptionSaving ClauseGovernmental PlansRemoval to Federal CourtSubject Matter JurisdictionNew York Insurance LawClass Action LitigationEmployee Benefits Plan
References
31
Case No. MISSING
Regular Panel Decision

Concerned Home Care Providers, Inc. v. Cuomo

Plaintiffs, an association of home care providers and five licensed home care services agencies, challenged the New York Public Health Law § 3614-c (Wage Parity Law), alleging preemption by NLRA and ERISA, and violations of Equal Protection and Due Process. The Court dismissed claims against Governor Andrew M. Cuomo and all claims related to NLRA preemption, Equal Protection, and Due Process. However, the Court denied dismissal of the ERISA preemption claim against Commissioner Nirav R. Shah, finding subdivision 4 of the Wage Parity Law invalid as preempted by ERISA. Consequently, subdivision 4 was severed, and Commissioner Shah was permanently enjoined from enforcing it, while the remainder of the Wage Parity Law was upheld.

Wage Parity LawERISA PreemptionNLRA PreemptionEqual ProtectionDue ProcessStandingSeverabilityHome Care ServicesMedicaidCollective Bargaining
References
14
Case No. MISSING
Regular Panel Decision

Coyne Electrical Contractors, Inc. v. United States (In Re Coyne Electrical Contractors, Inc.)

This case addresses whether a New York Lien Law "trust fund" beneficiary’s claim to priority payment under Lien Law Section 71(2)(d) is preempted by ERISA. The applicant, The Joint Industry Board of the Electrical Industry and its Participating Funds (JIB), sought priority payment from funds held by the debtor, asserting a claim for unpaid benefits. The defendant, A-J Contracting, Inc. (A-J), challenged this, arguing ERISA preemption, specifically that the Lien Law provided an "alternative enforcement mechanism" forbidden by ERISA. The court reviewed federal preemption doctrine and ERISA's objectives, ultimately concluding that Section 71(2)(d) does not create such a mechanism as it confirms existing employer liability rather than shifting it. Therefore, the court found that ERISA does not preempt JIB's assertion of priority rights under Lien Law Section 71(2)(d).

ERISA preemptionLien Law trust fundpriority disputeunpaid employee benefitsbankruptcy estatedebtor liabilityconstruction subcontractsfederal supremacystatutory interpretationcollective bargaining agreement
References
29
Case No. MISSING
Regular Panel Decision

Westbrook v. Beverly Enterprises

The case involves a plaintiff suing her employer, Beverly Enterprises, for negligence after an on-the-job injury. Beverly removed the case to federal court, arguing ERISA preemption because it offered an ERISA plan with a 'waiver of right to sue' clause instead of Workers' Compensation Insurance. The court examines its jurisdiction and finds that the plaintiff's common law negligence claims do not 'relate to' ERISA, nor does the 'waiver of right to sue' clause trigger ERISA preemption. The court distinguishes between claims against an employer as an administrator of a plan and claims arising from the traditional employer-employee relationship, concluding that the negligence claims fall under the latter. Therefore, the court remands the case to the state court.

ERISA preemptionnegligence claimemployer-employee relationshipstate court jurisdictionfederal court removalwaiver of right to sueworkers' compensationbenefit plancommon lawremand
References
18
Case No. MISSING
Regular Panel Decision

Corporate Health Insurance v. Texas Department of Insurance

This case involves a dispute over the preemption of Texas Senate Bill 386, the Health Care Liability Act, by federal laws ERISA and FEHBA. Plaintiffs, a group of health insurance companies, sought declaratory and injunctive relief against the Texas Department of Insurance, its Commissioner, and the Attorney General of Texas, arguing that the Act's provisions are preempted. The defendants filed a motion to dismiss (converted to summary judgment), and plaintiffs filed a cross-motion for summary judgment. The Court found that the Texas Department of Insurance was immune from suit under the Eleventh Amendment and dismissed it. While the court determined that the Act does not make express reference to ERISA plans and that claims challenging the quality of care provided are not preempted, it held that certain provisions mandating the structure and administration of plan benefits (specifically the Independent Review Organization (IRO) procedure) and provisions binding employers or plan administrators to particular choices (Sections 88.002(f) and (g) regarding physician removal and indemnification clauses) are preempted by ERISA and therefore severed them. The court also clarified that FEHBA preemption requires a case-by-case analysis and does not apply to quality of care claims. Consequently, the motions for summary judgment were granted in part and denied in part.

ERISA PreemptionFEHBA PreemptionHealth Care Liability ActManaged Care EntitiesState Law PreemptionSummary JudgmentDeclaratory JudgmentInjunctive ReliefIndependent Review OrganizationQuality of Care
References
0
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