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Ninth Circuit Reaffirms Broad ERISA Preemption Regardless of Concurrent ERISA Claim
Troutman Pepper Locke 
Dec. 7, 2025 "The panel's brief decision underscores that the Court's 2024 decision in Bristol Holdings applies broadly to state-law causes of action arising from pre-service verification-of-benefits and authorization communications, even where a provider also pleads an alternative ERISA benefits claim pursuant to an assignment of benefits from the member. ... [T]he disposition is a clear, persuasive affirmation of Bristol's reach." [Dedicato Treatment Center, Inc. v. Aetna Life Ins. Co., No. 26-6487 (9th Cir. Nov. 24, 2025; unpub.)] MORE >> |
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