3 pages. Excerpt: On September 30, 2008, the U.S. Court of Appeals for the Ninth Circuit ruled that ERISA does not preempt the employer spending requirement of the San Francisco Health Care Security Ordinance. (Golden Gate Rest. Ass'n v. City & County of San Francisco, No. 07-17370, slip op. (9th Cir. Sept. 30, 2008).) .... Golden Gate is a result-driven opinion that demonstrates the ever-increasing need for federal health care reform. The Ninth Circuit's protests notwithstanding, the decision effectively creates a split with the Fourth Circuit's Fielder decision as to whether state health care laws imposing pay or play requirements on employers are preempted by ERISA.  MORE >>