The Court wrote at some length in Access Mediquip v. United Healthcare to clarify earlier cases about preemption of state law tort claims by ERISA. Access claimed that United made representations about payment for certain medical devices for three insureds. The Court rejected a reading of Transitional Hospitals v. Blue Cross, 164 F.3d 952 (5th Cir. 1999), that would find preemption if an alleged misrepresentation dealt with the extent of coverage. Op. at 12-13. “The dispositive issue . . . is therefore whether Access’s state law claims are dependent on, and derived from the rights of [the three insureds] to recover benefits under the terms of their ERISA plans.” Op. at 13. Under that framework, the Court found that Access’s claims for misrepresentation were not preempted by Transitional, but its unjust enrichment and quantum meruit claims were. Op. at 18-19. The opinion synthesizes several prior cases in this complicated, technical area of preemption law.
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