349 P.3d 1171
Haw.2015Background
- Rodrigues, UPW State Director and MAF administrator, acted as ERISA fiduciary managing MAF assets.
- From 1998 he made six loans totaling $1.1 million to Best Rescue; the company did not repay.
- Federal district court held MAF ERISA plan and Rodrigues breached fiduciary duties, liable for five of six loans totaling $850,000; Ninth Circuit affirmed.
- In 2008 Rodrigues filed a Hawaii circuit court indemnity action seeking recovery of $850,000 plus fees from UPW, arguing UPW authorized/ratified his actions.
- UPW rejected indemnity, arguing ERISA preemption; circuit court granted summary judgment for UPW.
- The Hawaiʻi ICA affirmed on preemption grounds while noting negligence as an alternate basis; Hawaiʻi Supreme Court ultimately held ERISA preempts the state indemnity claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does ERISA preempt Rodrigues' indemnity claim? | Rodrigues argues no implied or express preemption since claim is not about plan benefits. | UPW argues ERISA preempts state indemnity claim. | ERISA preempts Rodrigues' indemnity claim. |
Key Cases Cited
- New York State Conf. of Blue Cross & Blue Shield Plans v. Travelers Ins. Co., 514 U.S. 645 (1995) (relate to preemption test guidance)
- District of Columbia v. Greater Washington Bd. of Trade, 506 U.S. 125 (1992) (statutory preemption reference considerations)
- Pilot Life Ins. Co. v. Dedeaux, 481 U.S. 41 (1987) (ERISA’s exclusive civil-enforcement mechanism)
- Boggs v. Boggs, 520 U.S. 833 (1997) (preemption depends on obstructing goals of ERISA)
- AFL Hotel & Restaurant Workers Health & Welfare Trust Fund v. Bosque, 110 Hawaiʻi 318 (2006) (state claims preempted where relying on plan administration)
- Garcia v. Hawaiʻi, 90 Hawaiʻi 425 (1999) (ERISA express preemption of claims by beneficiaries)