62 F. Supp. 3d 1360
S.D. Fla.2014Background
- Plaintiff Ungaro alleges Defendants owe $201,316.64 for medical services rendered to patients covered by Defendant’s health plan.
- Plaintiff’s First Amended Complaint asserts Counts II through VI (oral contract, third-party beneficiary contract, open account, unjust enrichment, and Florida Deceptive Trade Practices Act) in addition to Count I ERISA-based claim.
- Defendant removed the case to federal court, contending ERISA preempts state-law claims; Defendant also previously moved to dismiss (D.E. 7).
- The Court granted Defendant’s motion to dismiss Counts II–VI on defensive ERISA preemption grounds, finding the state-law claims relate to ERISA plans.
- Plaintiff withdrew Count III; the remaining counts were dismissed with prejudice and the related mootness motion was resolved.
- The order clarifies that the ERISA preemption defeats state-law claims seeking payment for services provided to insured members.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do Counts II–VI relate to ERISA plans and are preempted? | Ungaro argues claims may be pled in the alternative and may not relate to ERISA. | UNH asserts defensive preemption, as the claims relate to ERISA plans and payment for benefits. | Counts II–VI are defensively preempted and dismissed. |
Key Cases Cited
- Pilot Life Ins. Co. v. Dedeaux, 481 U.S. 41 (U.S. 1987) (preemption of benefit-denial-related claims under ERISA)
- Hall v. Blue Cross/Blue Shield of Ala., 134 F.3d 1063 (11th Cir. 1998) (conflict preemption for fraudulent inducement when policy documents control)
- Autonation, Inc. v. United Healthcare Ins. Co., 423 F. Supp. 2d 1265 (S.D. Fla. 2006) (state claims by ERISA-beneficiaries preempted when seeking benefits)
- Cantrell v. Currey, 407 F. Supp. 2d 1280 (M.D. Ala. 2005) (oral agreement entitling ERISA benefits implicates preemption)
- In re Managed Care Litig., 595 F. Supp. 2d 1349 (S.D. Fla. 2009) (ERISA preemption analysis for defensive preemption)
- Garren v. John Hancock Mut. Life Ins. Co., 114 F.3d 186 (11th Cir. 1997) ("Relates to" ERISA preemption standard)
- Cotton v. Mass. Mut. Life Ins. Co., 402 F.3d 1267 (11th Cir. 2005) (defensive preemption is broad and can defeat state claims)