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One-Person Individually-Negotiated Employment Agreement Not an ERISA Plan
Deloitte via BenefitsLink.com 
[Guidance Overview] Oct. 17, 2011
With regard to the employee's demands under the ERISA plans, the Court ruled that the state law remedies would be preempted; however, if the employee's demands were simply for payment of amounts that were pegged to what would have been paid under the ERISA plans, the state law remedies would not be preempted. The case was sent back to the district court for further proceeding in accordance with the Court's decision.
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