Swagelok Associates Welfare Benefits Plan v. Laura Patterson, et vir

Petitioner Swagelok Associates Welfare Benefits Plan (the “Plan”) provided medical benefits coverage to Respondent Laura Patterson when she was injured in an automobile accident. Ms. Patterson filed an action in the Ohio Court of Common Pleas, seeking a declaration that the Plan had no right to reimbursement out of Ms. Patterson’s potential third party recovery, and to “bar” the Plan from enforcing its reimbursement rights with respect to any potential recovery she received from a third party in connection with the accident. The Ohio Court of Appeals for the Ninth District, Summit County, construed the Pattersons’ claims as arising under both ERISA Section 502(a)(1)(B) and Section 502(a)(3), and held that, because the claim was, in part, a claim for benefits under Section 502(a)(1)(B), the state court had jurisdiction over the matter pursuant to ERISA Section 502(e)(1). The Ohio Supreme Court rejected the Plan’s request to take jurisdiction of an appeal, thereby affirming the Ohio Appellate Court’s ruling. The question presented is: Is a state law action brought by a Plan Participant for an injunction barring an ERISA welfare benefit plan from enforcing its subrogation/reimbursement terms a claim for equitable relief pursuant to ERISA Section 502(a)(3), 29 U.S.C. 1132(a)(3), and therefore a claim over which the federal courts have exclusive jurisdiction under Section 502(e)(1), 29 U.S.C. 1132(e)(1), or may such an action proceed in state court?