Arditi v. Lighthouse International, 676 F.3d 294

Arditi sued Lighthouse in state court seeking Plan benefits; suit removal to federal court was based on ERISA preemption; the district court held the claims preempted and dismissed for failure to state a claim; Arditi had rejoined Lighthouse in 2002 and signed an employment agreement referencing Plan benefits; Lighthouse amended and froze the Plan in 2007; Arditi retired in 2010 after the Plan freeze; the Court affirmed dismissal and remand-denial

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ERISA completely preempts the state-law claim	Arditi seeks independent non-Plan damages	Claims arise from Plan terms	Preemption upheld
Whether removal/remand was proper given ERISA preemption	District court should remand to state court	Removal proper under ERISA preemption	Removal proper; remand denied
Whether the complaint states a plausible claim after ERISA preemption	Independent contractual promise exists	Promises arise from Plan, not independent contract	Complaint dismissed for failure to state a claim
Whether Stevenson controls independent-duty analysis	Stevenson supports independent contract claim	Stevenson distinguishes facts; Plan context controls	Stevenson not controlling; ERISA preemption applies
Whether Arditi can prove an independent contract duty outside the Plan	Independent promise in employment agreement	No independent duty; Plan governs benefits	Not permitted; ERISA preemption stands

Aetna Health Inc. v. Davila, 542 U.S. 200 (U.S. 2004) (well-pleaded complaint rule and complete preemption)
Beneficial Nat. Bank v. Anderson, 539 U.S. 1 (U.S. 2003) (ERISA preemption scope; supremacy of federal regime)
Montefiore Med. Ctr. v. Teamsters Local 272, 642 F.3d 321 (2d Cir. 2011) (two-prong Davila test; independent-duty notion)
Stevenson v. Bank of N.Y. Co., 609 F.3d 56 (2d Cir. 2010) (independent contract-based duty not arising from plan terms)
Rivet v. Regions Bank, 522 U.S. 470 (U.S. 1998) (removal; preemption considerations)