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Tenth Circuit Determines Plaintiff Has No Standing to Bring Suit Under ERISA, So His Claim Cannot Be Removed to Federal Court
ERISA Lawyer Blog 
[Guidance Overview] Apr. 21, 2011
The doctrine of complete preemption, discussed in this case, is separate and apart from ERISA's preemption of state law found in Section 514(a) of ERISA. The complete preemption creates federal jurisdiction, while Section 514(a) preemption is a defense to a state law claim pertaining to an employee benefit plan.
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