GARRICK COX MD LLC v. UNITED HEALTHCARE INSURANCE COMPANY, 2:17-cv-08186

Plaintiff Garrick Cox MD LLC, a New Jersey medical provider, sued "United Healthcare" in New Jersey state court seeking unpaid fees for surgeries (two related cases seeking ~$301,728 and ~$613,847).
Plaintiff alleges United authorized procedures and promised payment, then underpaid; claims pleaded as contract/quasi-contract, not ERISA benefits claims.
United removed both suits to federal court asserting complete preemption by ERISA §502(a) and that the claims actually seek plan benefits.
Plaintiff moved to remand; the district judge referred the motions to the magistrate judge for a Report and Recommendation.
The magistrate judge found United failed to carry its burden to show federal jurisdiction and recommended remand to New Jersey Superior Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether removal is proper via ERISA complete preemption	Cox says claims are ordinary contract/quasi-contracts independent of ERISA	United says claims necessarily seek ERISA-plan benefits and are completely preempted	Remand recommended — United did not show complete preemption
Whether plaintiff could have brought the pleaded claims under ERISA §502(a)	Cox: pleadings do not allege participant/beneficiary status or valid assignments	United: factual context (insurance/payment, prior authorizations) implies ERISA-plan benefit claims	Held for Cox — no pleading that fits §502(a) categories; United failed to show claim could have been brought under §502(a)
Whether an independent legal duty supports the state-law claims	Cox: alleges separate agreements with United creating independent duties	United: plaintiff’s sparse pleadings actually depend on plan duties; merits challenge	Held for Cox — duties alleged would exist regardless of any ERISA plan; no plan interpretation appears necessary
Whether factual/merits doubts justify federal jurisdiction or discovery into assignments	Cox: plaintiff is master of complaint; limited factual allegations avoid ERISA	United: asks court to read extra facts (assignments/plan membership) into complaint or allow discovery	Held for Cox — court will not rewrite the complaint or assume facts; United’s discovery arguments insufficient to establish federal jurisdiction

Caterpillar Inc. v. Williams, 482 U.S. 386 (establishes well-pleaded complaint rule)
Lincoln Property Co. v. Roche, 546 U.S. 81 (complete diversity requirement)
Franchise Tax Board of California v. Construction Laborers Vacation Trust for Southern California, 463 U.S. 1 (federal-question arising-under test)
Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturing, 545 U.S. 308 (when state claims present substantial federal issues)
Trans Penn Wax Corp. v. McCandless, 50 F.3d 217 (3d Cir.) (well-pleaded complaint rule and defense preemption)
Pascack Valley Hospital, Inc. v. Local 464A UFCW Welfare Reimbursement Plan, 388 F.3d 393 (3d Cir.) (two-prong ERISA complete preemption test)
Aetna Health Inc. v. Davila, 542 U.S. 200 (ERISA §502(a) as complete preemption)
Metropolitan Life Insurance Co. v. Taylor, 481 U.S. 58 (ERISA preemption principles)
N.J. Carpenters Health Fund v. Tishman Construction Corp., 760 F.3d 297 (3d Cir.) (application of Pascack test)
Lynch v. Pierce, Fenner & Smith, Inc., 772 F.3d 158 (3d Cir.) (burden on the removing party)
Marin General Hospital v. Modesto & Empire Traction Co., 581 F.3d 941 (9th Cir.) (independent legal duty concept)
Gardner v. Heartland Industrial Partners, LP, 715 F.3d 609 (6th Cir.) (duty independent of ERISA plan)