Aetna Health Inc. v. Davila — June 2004 (Summary)

ERISA PREEMPTION

Aetna Health Inc. v. Davila
Nos. 02-1845, 03-83 (U.S. June 21, 2004)

The United States Supreme Court held that two beneficiaries’ claims that their HMOs violated the Texas Health Care Liability Act by denying coverage for certain medical services were completely preempted by the ERISA. The Court stated that is was Congress’s intent that ERISA enforcement and employee benefit plan regulation be exclusively a federal concern, and thus any state-law cause of action which supplements or supplants ERISA’s enforcement is preempted. The Court further stated that if an individual, at any point in time, could have brought suit under ERISA, then the individual’s cause of action is preempted.