Eric Patterson v. UnitedHealth Group, Inc. -Northern District of Ohio at Cleveland
Split Score
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Case Summary
Disposition
Affirmed
The Sixth Circuit held that Eric Patterson’s state-law fraud, conversion, unjust-enrichment, and conspiracy claims—filed over his insurer’s collection of $25,000 in accident-recovery reimbursement—are completely pre-empted by ERISA. Applying the two-step Davila test, the Court ruled that the claims seek benefits due under the plan and depend entirely on plan terms, affirmed removal, and permitted dismissal to avoid duplicative litigation already pending under ERISA.
Circuit Split Identified
Legal Issue
Whether state-law suits challenging an ERISA plan’s asserted reimbursement right are completely pre-empted by ERISA and therefore removable under 29 U.S.C. § 1132(a)(1)(B).
Circuit Positions
State-law challenges to ERISA reimbursement demands are completely pre-empted under § 1132(a)(1)(B) (removable).
Such challenges are not completely pre-empted because they arise under state insurance law, not plan terms.
Conflict Summary
Most circuits hold that a beneficiary’s state-law challenge to a plan’s reimbursement claw-back is, in essence, a claim to recover benefits due under § 1132(a)(1)(B) and is therefore completely pre-empted and removable to federal court. The Second Circuit, by contrast, treats such claims as based on independent state insurance law duties and not pre-empted under Davila’s first prong.