Aetna Health, Inc. v. Davila
United States Supreme Court
542 U.S. 200 (2004)
Davila and Calad (plaintiffs, cases consolidated) each had employer-sponsored health coverage through insurers regulated by ERISA. Davila's insurer refused to cover a prescribed drug, and he suffered a serious reaction to the substitute; Calad's insurer denied an extended hospital stay after surgery, and she suffered complications requiring readmission. Each sued their insurer in Texas state court under the Texas Health Care Liability Act, alleging a failure to exercise ordinary care in making coverage decisions; the cases were removed to federal court and dismissed as preempted by ERISA, and the Fifth Circuit reversed, finding the claims didn't fit ERISA's civil-enforcement provisions.
Whether a state-law claim complaining of a denial of medical coverage under an ERISA-regulated benefit plan, where no legal duty independent of the plan or of ERISA is violated, is preempted by ERISA § 502(a)(1)(B).