Access Mediquip L.L.C. v. Unitedhealthcare Insurance
662 F.3d 376
| 5th Cir. | 2011Background
- Access procures and finances medical devices for health care providers, typically after confirming insurer reimbursement before proceeding.
- Access’s claims arise from United’s alleged misrepresentations about paying reasonable charges for devices and related services for ERISA-insured patients.
- The district court limited discovery to the 300 patients with the largest reimbursement requests, then focused on three exemplar patients (L.G., L.C., D.T.) for preemption analysis.
- District court held all state-law claims relating to those three patients preempted under ERISA § 1144(a).
- On appeal, the Fifth Circuit reversed in part and affirmed in part: promissory estoppel, negligent misrepresentation, and Texas Insurance Code claims are not preempted; quantum meruit and unjust enrichment claims are preempted; remanded for proceedings consistent with the opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are misrepresentation claims preempted by ERISA? | Access contends misrepresentation claims are not prempted because they target third-party representations about coverage, not plan administration. | United contends misrepresentation claims relate to benefit determinations and are thus ERISA-preempted. | Misrepresentation claims not preempted. |
| Are unjust enrichment and quantum meruit claims preempted by ERISA? | Access argues these claims do not depend on plan terms and thus are not preempted. | United argues these claims depend on plan benefits and are preempted by ERISA. | Unjust enrichment and quantum meruit preempted. |
| Are promissory estoppel, negligent misrepresentation, and Texas Insurance Code claims preempted? | Access asserts these claims are based on third-party representations independent of plan terms. | United contends these claims implicate ERISA plan terms and administration. | Promissory estoppel, negligent misrepresentation, and Texas Insurance Code claims not preempted. |
Key Cases Cited
- Memorial Hospital System v. Northbrook Life Ins. Co., 904 F.2d 246 (5th Cir. 1990) (ERISA preemption framework for misrepresentation claims involving coverage verifications)
- Transitional Hospitals Corp. v. Blue Cross & Blue Shield of Tex., 164 F.3d 952 (5th Cir. 1999) (nonpreemption for misrepresentation about extent of coverage; informs Memorial approach)
- Egelhoff v. Egelhoff ex rel. Breiner, 532 U.S. 141 (U.S. 2001) (statutory gloss on ERISA preemption scope)
- Travelers Ins. Co. v. Communications Workers of Am., 514 U.S. 645 (U.S. 1995) (limitations on literal interpretation of 'relate to' in ERISA preemption)
- Mayeaux v. La. Health Serv. and Indem. Co., 376 F.3d 433 (5th Cir. 2004) (test for when state-law claims relate to ERISA plan terms and entities)