542 U.S. 200, 209 (2004)
Juan Davila was a participant and Ruby Calad a beneficiary in ERISA-regulated employee benefit plans.1 Their plan sponsors contracted with Aetna Health Inc. and CIGNA Healthcare of Texas, Inc., respectively, to administer the plans and make coverage decisions.2
Davila's physician prescribed Vioxx for his arthritis, but Aetna denied coverage.3 Davila took Naprosyn instead and suffered a severe reaction necessitating hospitalization.4 After Calad's surgery, CIGNA denied coverage for an extended hospital stay recommended by her physician, leading to postsurgical complications upon her return home.5
Respondents filed separate suits in Texas state court under the Texas Health Care Liability Act.6 They alleged that the HMOs failed to exercise ordinary care in coverage decisions and that these failures proximately caused their injuries. Petitioners removed the actions to federal district courts on the ground that the claims were completely preempted by ERISA.7 The district courts denied remand and dismissed the complaints with prejudice after respondents declined to replead under ERISA.8
The Fifth Circuit consolidated the appeals with similar cases and reversed the district courts' judgments.9 The Supreme Court granted certiorari to review whether the causes of action are completely preempted by ERISA § 502(a).10
Whether the causes of action asserted under the Texas Health Care Liability Act are completely preempted by ERISA § 502(a)?11
If an individual, at some point in time, could have brought his claim under ERISA § 502(a)(1)(B), and where there is no other independent legal duty that is implicated by a defendant’s actions, then the individual’s cause of action is completely pre-empted by ERISA § 502(a)(1)(B).12 Any state-law cause of action that duplicates, supplements, or supplants the ERISA civil enforcement remedy conflicts with the clear congressional intent to make the ERISA remedy exclusive and is therefore pre-empted.13
Yes. Juan Davila was a participant and Ruby Calad a beneficiary in ERISA-regulated employee benefit plans. Their plan sponsors contracted with Aetna Health Inc. and CIGNA Healthcare of Texas, Inc., respectively, to administer the plans and make coverage decisions.
Davila's physician prescribed Vioxx for his arthritis, but Aetna denied coverage. Davila took Naprosyn instead and suffered a severe reaction necessitating hospitalization. After Calad's surgery, CIGNA denied coverage for an extended hospital stay recommended by her physician, leading to postsurgical complications upon her return home.
Respondents filed separate suits in Texas state court under the Texas Health Care Liability Act. They alleged that the HMOs failed to exercise ordinary care in coverage decisions and that these failures proximately caused their injuries. Petitioners removed the actions to federal district courts on the ground that the claims were completely preempted by ERISA. The district courts denied remand and dismissed the complaints with prejudice after respondents declined to replead under ERISA.
The Fifth Circuit consolidated the appeals with similar cases and reversed the district courts' judgments. The Supreme Court granted certiorari to review whether the causes of action are completely preempted by ERISA § 502(a). Applying the rule, respondents complain only about denials of coverage promised under the terms of ERISA-regulated employee benefit plans.14 Upon the denial of benefits, respondents could have paid for the treatment themselves and then sought reimbursement through a § 502(a)(1)(B) action.15 The duties imposed by the THCLA in these cases do not arise independently of ERISA or the plan terms, as the THCLA explicitly states that it creates no obligation to provide treatment not covered by the plan.16 Interpretation of the terms of respondents’ benefit plans therefore forms an essential part of their THCLA claim, and THCLA liability exists here only because of petitioners’ administration of ERISA-regulated benefit plans.17 The claims fall within the scope of ERISA § 502(a)(1)(B) and are completely preempted.18
The causes of action are completely preempted by ERISA § 502(a) and removable to federal court.19
Related opinions on this issue
Joined by Justice Breyer
Justice Ginsburg, joined by Justice Breyer, concurred in the judgment.20 She observed that the Court's encompassing interpretation of ERISA preemption paired with a cramped construction of equitable relief under § 502(a)(3) has produced a regulatory vacuum in which persons harmed by ERISA-proscribed wrongdoing cannot obtain make-whole relief.21 She pointed to prior decisions that limited remedies for consequential injuries.22
She called for fresh consideration of the availability of consequential damages under § 502(a)(3), noting that either Congress or the Court should realign ERISA remedy law with the trust remedial tradition that includes the make-whole standard of relief.23