Retail Industry Leaders Association v. Fielder
Fourth Circuit
475 F.3d 180 (2007)
Maryland's Fair Share Health Care Fund Act (the Act) required employers with 10,000 or more Maryland employees to spend at least 8 percent of payroll on health insurance or pay the shortfall to the state; only Wal-Mart met that threshold, and Maryland lawmakers openly designed the law to force Wal-Mart to boost its employee health benefits. The Retail Industry Leaders Association (the Association) (plaintiff), of which Wal-Mart was a member, sued James Fielder, Maryland's labor secretary (defendant), to have the Act declared preempted by the Employee Retirement Income Security Act (ERISA) and to block its enforcement. The district court ruled for the Association, and Fielder appealed.
Whether a state law that has any "connection with" or "reference to" an employee benefit plan is preempted by ERISA.