context: Reducing the Van Nattas' complaint to its core reveals the fact that all of their state law claims are premised upon alleged improper processing of a claim for benefits under an employee-benefit plan. As the Supreme Court and Eighth Circuit have previously reiterated, such claims undoubtedly meet the criteria for preemption under SS 514(a), even if the state statutes at issue do not expressly make reference to ERISA plans.
citation_a.signal: see
citation_a.parenthetical: finding that the plaintiffs claims, each based on alleged improper processing of a claim for benefits under a qualified ERISA plan, "undoubtedly" met the criteria for preemption under SS 514(a
citation_a.sentence: See Pilot Life Ins. Co., 481 U.S. at 47-48, 107 S.Ct. 1549 (finding that the plaintiffs claims, each based on alleged improper processing of a claim for benefits under a qualified ERISA plan, “undoubtedly” met the criteria for preemption under § 514(a), despite the fact the state laws at issue did not expressly reference ERISA plans); Kuhl, 999 F.2d at 302 (having no difficulty concluding the plaintiffs’ claims, all arising from the administration of benefits under a qualified ERISA plan were preempted by ERISA); see also Parkman v. Prudential Ins. Co. of Am., 439 F.3d 767, 771-72 (8th Cir.2006) (“ERISA preempts ‘state common law tort and contract actions asserting improper processing of a claim for benefits’ under an ERISA plan.”) (quoting Pilot Life Ins. Co.); Fink v. Dakotacare, 324 F.3d 685, 689 (8th Cir.2003) (holding that state law causes of action arising from improper processing of a claim for benefits are preempted); Howard v. Coventry Health Care, of Iowa, Inc., 293 F.3d 442, 446 (8th Cir.2002) (holding that the plaintiffs’ causes of action were preempted because their claims were premised on the existence of an ERISA plan); Thompson v. Gencare Health Sys., Inc., 202 F.3d 1072, 1073 (8th Cir.2000) (“ERISA remedies preempt ‘state common law tort and contract actions asserting improper processing of a claim for benefits’ under an ERISA plan.”) (quoting Pilot Life Ins. Co.); Hull v. Fallon, 188 F.3d 939, 943 (8th Cir.1999) (holding that where the basis of state claims for medical malpractice relates to the administration of plan benefits, those claims “fall squarely within the scope” of ERISA); accord McDonald v. Household Int’l, Inc., 425 F.3d 424, 429 (7th Cir.2005) (finding that the plaintiffs state law claims premised on the defendants’ failure to give the plaintiff the benefits under the medical plan he had been promised were preempted); Gilbert v. Burlington Indus., Inc., 765 F.2d 320, 328 (2d Cir.1985) (citing numerous cases finding claims for recovery of benefits preempted by ERISA), aff'd, 477 U.S. 901, 106 S.Ct. 3267, 91 L.Ed.2d 558 (1986); Schwartz v. Newsweek, Inc., 653 F.Supp. 384, 389 (S.D.N.Y.1986) (citing decisions holding claims for recovery of alleged benefits preempted under ERISA), aff'd, 827 F.2d 879 (1987).
citation_b.signal: see also
citation_b.identifier: 324 F.3d 685, 689
citation_b.parenthetical: holding that state law causes of action arising from improper processing of a claim for benefits are preempted
citation_b.sentence: See Pilot Life Ins. Co., 481 U.S. at 47-48, 107 S.Ct. 1549 (finding that the plaintiffs claims, each based on alleged improper processing of a claim for benefits under a qualified ERISA plan, “undoubtedly” met the criteria for preemption under § 514(a), despite the fact the state laws at issue did not expressly reference ERISA plans); Kuhl, 999 F.2d at 302 (having no difficulty concluding the plaintiffs’ claims, all arising from the administration of benefits under a qualified ERISA plan were preempted by ERISA); see also Parkman v. Prudential Ins. Co. of Am., 439 F.3d 767, 771-72 (8th Cir.2006) (“ERISA preempts ‘state common law tort and contract actions asserting improper processing of a claim for benefits’ under an ERISA plan.”) (quoting Pilot Life Ins. Co.); Fink v. Dakotacare, 324 F.3d 685, 689 (8th Cir.2003) (holding that state law causes of action arising from improper processing of a claim for benefits are preempted); Howard v. Coventry Health Care, of Iowa, Inc., 293 F.3d 442, 446 (8th Cir.2002) (holding that the plaintiffs’ causes of action were preempted because their claims were premised on the existence of an ERISA plan); Thompson v. Gencare Health Sys., Inc., 202 F.3d 1072, 1073 (8th Cir.2000) (“ERISA remedies preempt ‘state common law tort and contract actions asserting improper processing of a claim for benefits’ under an ERISA plan.”) (quoting Pilot Life Ins. Co.); Hull v. Fallon, 188 F.3d 939, 943 (8th Cir.1999) (holding that where the basis of state claims for medical malpractice relates to the administration of plan benefits, those claims “fall squarely within the scope” of ERISA); accord McDonald v. Household Int’l, Inc., 425 F.3d 424, 429 (7th Cir.2005) (finding that the plaintiffs state law claims premised on the defendants’ failure to give the plaintiff the benefits under the medical plan he had been promised were preempted); Gilbert v. Burlington Indus., Inc., 765 F.2d 320, 328 (2d Cir.1985) (citing numerous cases finding claims for recovery of benefits preempted by ERISA), aff'd, 477 U.S. 901, 106 S.Ct. 3267, 91 L.Ed.2d 558 (1986); Schwartz v. Newsweek, Inc., 653 F.Supp. 384, 389 (S.D.N.Y.1986) (citing decisions holding claims for recovery of alleged benefits preempted under ERISA), aff'd, 827 F.2d 879 (1987).