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Sixth Circuit Holds ERISA Preempts Tennessee PBM Laws
Roberts Disability Law 
Apr. 8, 2026 "[T]he court held that both categories of PBM laws had an impermissible 'connection with' ERISA plans under 29 U.S.C. Section 1144(a). Applying the framework from Rutledge and Gobeille ... the court identified three independent grounds for preemption: the laws [1] required providers to structure benefit plans in a particular way, [2] governed a central matter of plan administration, and [3] interfered with nationally uniform plan administration." [McKee Foods Corporation v. BFP Inc., No. 25-5416 (6th Cir. Apr. 7, 2026)] MORE >> |
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