Gobeille v. Liberty Mut. Ins. Co.
136 S. Ct. 936
| SCOTUS | 2016Background
- Vermont enacted an all-payer claims database statute (18 V.S.A. §9410) and implementing regulation requiring submission of detailed claims, eligibility, pharmacy, and provider data from insurers and other payers; entities with ≥200 Vermont members must report.
- Liberty Mutual sponsors a nationwide, self-insured ERISA welfare benefit plan administered by Blue Cross; Liberty is a "voluntary" reporter (fewer than 200 Vermonters) but Blue Cross is a mandated reporter and received a Vermont subpoena for Liberty plan data.
- Liberty instructed Blue Cross not to comply and sued, seeking declaratory and injunctive relief that ERISA preempts Vermont's reporting law as applied to ERISA plans.
- District Court upheld Vermont's law; the Second Circuit reversed, holding ERISA preempts the state reporting regime as applied to ERISA plans.
- The Supreme Court affirmed the Second Circuit: ERISA's preemption clause bars Vermont from enforcing its reporting requirements against ERISA-covered plans because they intrude on ERISA's uniform reporting, disclosure, and recordkeeping scheme.
Issues
| Issue | Plaintiff's Argument (Liberty) | Defendant's Argument (Vermont) | Held |
|---|---|---|---|
| Whether Vermont's reporting law "relates to" ERISA plans such that ERISA preempts it | State reporting compels plan-level claims disclosure and thus intrudes on ERISA-covered plan administration and uniform federal scheme | Law is generally applicable to all payers and aims to improve public health and cost transparency, not to regulate ERISA plans | Held: Preempted — law has forbidden connection with ERISA plans because it regulates core plan reporting/recordkeeping |
| Whether reporting/disclosure duties are a "central matter of plan administration" subject to federal exclusivity | ERISA contemplates uniform, centralized reporting/disclosure/recordkeeping; multiple state schemes would burden national plan administration | Vermont's data serves different objectives (health policy, market oversight) and does not regulate plan solvency or fiduciary administration | Held: Preempted — reporting/disclosure/recordkeeping are central ERISA functions; state regime would interfere with national uniformity |
| Whether the ACA's reporting additions alter preemption analysis | Liberty contends ACA incorporation supports federal primacy over reporting | Vermont points to ACA anti-preemption language and contends federal action does not foreclose state role | Held: Not decided on ACA grounds — Court rests decision on pre-existing ERISA reporting provisions, which suffice to preempt state law |
Key Cases Cited
- New York State Conference of Blue Cross & Blue Shield Plans v. Travelers Ins. Co., 514 U.S. 645 (establishes limits and tests for ERISA preemption; "reference to" and "connection with" formulations)
- Egelhoff v. Egelhoff, 532 U.S. 141 (state law impermissibly preempted when it governs a central matter of plan administration and undermines uniform administration)
- California Division of Labor Standards Enforcement v. Dillingham Construction, 519 U.S. 316 (use of ERISA objectives and effects to delimit preemption)
- De Buono v. NYSA-ILA Medical & Clinical Services Fund, 520 U.S. 806 (upholding generally applicable state tax/reporting obligations that do not regulate core plan administration)