RUNFOLA, ROSS T. v. SIEGEL, KELLEHER & KAHN
CA 11-01106
| N.Y. App. Div. | Nov 18, 2011Background
- Plaintiff, a former partner of Siegel, Kelleher & Kahn (SKK), sued SKK and individual partners for breach of contract, fraud, and promissory estoppel.
- In 1992, SKK purchased a group long-term disability policy for the firm’s partners and circulated an internal notice outlining coverage.
- Plaintiff suffered multiple health issues over years but continued to work; his ability to practice law became impaired.
- The group disability policy lapsed in December 1997 due to nonpayment of premiums; plaintiff alleges he was not notified of the lapse.
- Plaintiff remained employed at SKK until May 2001 and then commenced the action seeking relief.
- Supreme Court granted some summary-judgment motions but left remaining causes, which the court later held were preempted by ERISA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does ERISA preempt plaintiff's state-law claims? | Plaintiff argues the claims arise from non-ERISA rights and should proceed. | Defendants contend ERISA preempts any claims relating to the employee benefit plan. | All remaining claims are preempted by ERISA. |
Key Cases Cited
- California Div. of Labor Stds. Enforcement v. Dillingham Constr., N.A., Inc., 519 U.S. 316 (U.S. 1997) (ERISA preemption scope includes plans and related disclosures)
- Ingersoll-Rand Co. v. McClendon, 498 U.S. 133 (U.S. 1991) (ERISA preemption broad interpretation)
- Shaw v. Delta Air Lines, Inc., 463 U.S. 85 (U.S. 1983) (definition of what constitutes a relation to an employee benefit plan)
- Matter of Council of City of N.Y. v Bloomberg, 6 N.Y.3d 380 (N.Y. 2005) (state-law claims preempted when connected to ERISA plans)