"All of the characteristics of the Basic Policies and Supplemental Coverage indicate that they are not two separate sources of coverage, but two parts of one broader benefits plan. All of the Basic Policies and Supplemental Coverage were governed by a single group contract between [the employer] and Prudential.... [We] hold that the Supplemental Coverage cannot be unbundled from the Basic Plans. In so holding, we join every Court of Appeals to have considered whether to unbundle closely related components of an employer's broader ERISA benefits plan and declined to do so.... The plaintiffs' claims fall into three broad categories ... In the circumstances presented here, ERISA preempts all three sets of claims." [Menkes v. Prudential Ins. Co. of America, No. 13-1408 (3d Cir. Aug. 6, 2014)]

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