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Text of Federal District Court Opinion: ERISA Preempts State Law Claim of Insurer Attempting to Recover Duplicative Benefit Payments (PDF)
U.S. District Court for the District of New Jersey Link to more items from this source
Sept. 23, 2014
"No matter how MetLife frames its arguments, both of MetLife's proposed state law claims are premised upon and require a finding that MetLife was not required, under the Plan's terms, to make the optional coverage benefit payment.... Although a state law claim that only 'requires a cursory examination of plan provisions' or arises in the context of an ERISA plan, may not be preempted by Section 514(a), the proposed state law claims in this case clearly arise from an ERISA plan, direct the Court's inquiry to the Plan, require an analysis of the Plan 's terms, and involve the calculation and payment of benefits due to a Plan participant. Therefore, MetLife's proposed state law claims are preempted by Section 514(a)." [Metropolitan Life Ins. Co. v. DePalo, No. 13-3092 (D.N.J. Sept. 22, 2014)]

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