Jackson Ridge Rehabilitation and Care, et al. v. Rhonda Meadows

The Employee Retirement Income Security Act of 1974 (hereinafter, “ERISA”), 29 U.S.C. §1001 et seq., was enacted to protect employee benefit plan participants from the mismanagement of welfare benefit plans by establishing uniform federal regulations. To safeguard employee benefit plan participants, §1140 makes it unlawful for an employer to take adverse employment action “against a participant or beneficiary for exercising any right to which he is entitled under the provisions of an employee benefit plan” or “for the purpose of interfering with the attainment of any right to which such participant may become entitled under the plan.” 29 U.S.C. §1140. Benefit plan participants enforce these rights through either §1132(a)(1)(B) or §1132(a)(3), depending on the nature of the claim. Federal courts have “exclusive jurisdiction” to adjudicate ERISA claims, unless the claims arise under §1132(a)(1)(B). 29 U.S.C. §1132(e)(1). By dismissing Petitioner’s appeal, the Ohio Supreme Court has construed ERISA claims for retaliation and interference to be enforced through §1132(a)(1)(B), thereby subjecting those claims to concurrent jurisdiction. The Ohio Supreme Court’s decision has created a conflict within the Sixth Circuit and among other federal courts. The question presented is: Whether ERISA claims for retaliation and interference are enforced through 29 U.S.C. §1132(a)(1)(B), as decided by the Ohio Supreme Court