Laurel Hill Mgmt. Servs., Inc v. La-Z-Boy Inc. -Eastern District of Michigan at Detroit
Split Score
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Case Summary
Disposition
Affirmed
The Sixth Circuit held that ERISA expressly preempts state-law negligent-misrepresentation and promissory-estoppel claims brought by out-of-network medical providers against La-Z-Boy’s plan administrator, Blue Cross Blue Shield of Michigan. Relying on its earlier decision in Cromwell, the court affirmed the district court’s dismissal with prejudice and declined to allow a post-judgment amendment.
Circuit Split Identified
Legal Issue
Whether ERISA’s express-preemption clause, 29 U.S.C. § 1144(a), bars state-law misrepresentation/promissory-estoppel claims by medical providers based on a plan administrator’s oral assurances about coverage or reimbursement terms of an ERISA plan.
Circuit Positions
ERISA preempts medical-provider negligent-misrepresentation and promissory-estoppel claims arising from an administrator’s oral statements about plan coverage/reimbursement.
ERISA does NOT preempt such state-law claims where the provider relies on independent tort or contract duties separate from the plan terms.
Conflict Summary
The Sixth Circuit (following Cromwell) holds that such claims are preempted because they seek, in essence, plan benefits and thus "relate to" the ERISA plan, while multiple other circuits permit providers to pursue state-law misrepresentation or related contract/tort remedies when the alleged duties arise independently of the plan terms.