Integris Health, Inc. v. Elizabeth Cates

The Employee Retirement Income Security Act, 29 U.S.C. §§ 1001 et seq. (“ERISA”), expressly preempts any and all state laws that “relate to” an employee benefit plan. 29 U.S.C. § 1144(a). Neither an agreement that an employee benefit plan makes with a hospital for the provision of network plan benefits, nor the fact that the hospital is the defendant in a participant’s action for those benefits, avoids ERISA express preemption. In holding otherwise with respect to putative class action state law claims, the Oklahoma Supreme Court purports to overturn decades of this Court’s jurisprudence. See Ingersoll-Rand Co. v. McClendon, 498 U.S. 133 (1990). The question presented is: Whether the Oklahoma Supreme Court misapplied 29 U.S.C. § 1144(a) and disregarded this Court’s precedent in holding that state law claims brought by a plan participant asserting rights to provider network benefits under an employee benefit plan do not “relate to” the plan for purposes of ERISA express preemption.