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Citing ERISA Preemption, Sixth Circuit Dismisses State-Law Claims
The Wood Law Firm, PLLC
[Guidance Overview] Apr. 26, 2009
Excerpt: The Sixth Circuit rejected Lerner's [the plaintiff] arguments that his state-law claims against EDS were based not on Continental's denial of long-term disability benefits, but on EDS's alleged failure to make sure that his SDRC benefits were not diminished in the corporate transition. The Court pointed out that Lerner had specifically pled in his state-law claims that his damages included 'the loss of disability insurance benefits (monthly benefit payments, return to work benefits, and rehabilitation benefits.)' In the view of the Court, 'Lerner has thus chosen to seek payment of the disability insurance benefits themselves, not merely damages in an amount equal to those benefits.' Therefore, the Court said, 'the state-law claims against EDS for breach of contract, fraudulent misrepresentation, and innocent misrepresentation 'relate to' an ERISA benefit plan and are preempted by that federal statute.'
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