40 pages. Excerpt: If the San Francisco Health Care Security Ordinance ... is allowed to circumvent ERISA's preemption provision, the Ordinance would subvert fundamental policies that Congress sought to advance when it enacted ERISA. Directly contrary to the voluntary employee benefit regime established by ERISA, the Ordinance would (1) require covered employers to provide health coverage, (2) specify how much a covered employer must spend on health care coverage, and (3) prevent covered employers with operations in San Francisco ... and in any other jurisdiction that adopts similar legislation, from maintaining health care plans that operate uniformly nationwide. The cost of complying with the resulting patchwork quilt of state and local health care laws will be borne by both employers and employees.

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