Benson v. Innovis Health, LLC
3:15-cv-00047
D.N.D.Oct 26, 2015Background
- Benson sued Innovis Health in state court for breach of contract over severance benefits; Innovis removed to federal court asserting ERISA preemption.
- Benson’s employment agreement ties severance to an Innovis severance plan; dispute centers on which plan applied.
- All severance plans at issue are ERISA plans, according to Innovis; Benson contends the dispute involves only state law contract interpretation.
- Innovis argues Benson’s claim is completely preempted under ERISA § 502(a)(1)(B) and thus falls within federal question jurisdiction.
- Court applies Davila two-part test for complete preemption and concludes there is federal question jurisdiction; remand is denied.
- Attorney-fees request under 28 U.S.C. § 1447(c) is to be denied; if remand were granted, fees would still be denied; no improper removal shown.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Benson’s claim is completely preempted by ERISA. | Benson asserts only a contract claim under North Dakota law. | Innovis argues the severance plan terms and benefits are ERISA plans; claim preempted. | Yes; complete preemption applies under Davila. |
| Whether removal to federal court was proper given ERISA preemption. | Remand urged due to lack of federal question. | Removal proper because ERISA preempts state-law claim. | Yes; removal proper. |
| Whether attorney fees should be awarded if remand denied. | Requests fees under § 1447(c) if remand granted. | Fees unnecessary where removal was reasonable and questions debatable. | Denied; even if remand granted, fees denied. |
Key Cases Cited
- Aetna Health Inc. v. Davila, 542 U.S. 200 (U.S. 2004) (ERISA preemption and complete preemption framework)
- Beneficial Nat’l Bank v. Anderson, 539 U.S. 1 (U.S. 2003) (complete preemption concept; preemption as jurisdictional)
- Metropolitan Life Ins. Co. v. Taylor, 481 U.S. 58 (U.S. 1987) (illustrates ERISA preemption concepts)
- Arditi v. Lighthouse Int’l, 676 F.3d 294 (2d Cir. 2012) (employment contract claim preempted when plan governs damages)
- Van Natta v. Sara Lee Corp., 439 F. Supp. 2d 911 (N.D. Iowa 2006) (preemption analysis across ERISA plans and state claims)
- Noel v. Laclede Gas Co., 612 F. Supp. 2d 1051 (E.D. Mo. 2009) (statutory notice claims deemed dependent on ERISA plans)
- Schieffer v. Dakota, Minn. & E.R.R. Corp., 857 F. Supp. 2d 886 (D.S.D. 2012) (example of complete preemption analysis under ERISA)