"The [Michigan Health Insurance Claims Assessment Act] imposes an assessment of 1% on the value of all claims paid by every carrier or third party administrator for medical services that are rendered in Michigan to a resident of Michigan.... As defined in the Act, the word 'carrier' includes, inter alia, certain 'group health plan sponsor[s].... [This Court] concludes that the Act does not have an impermissible 'connection with' an ERISA plan. Because the Court has already concluded that the Act does not impermissibly 'refer to' an ERISA plan, it does not 'relate to' ERISA under either prong of the preemption analysis and is therefore not preempted under [ERISA section] 514(a)." [Self-Insurance Institute of America, Inc. v. Snyder, No. 11-15602 (E.D. Mich., Sept. 7, 2012)]

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