finding that the district court properly denied motion to remand where an employee who had been denied disability benefits by employee benefits plan sought “compensatory damages for money contractually owed Plaintiff, compensation for mental anguish caused by breach of this contract, as well as immediate reimplementation of all benefits and insurance coverages Plaintiff is entitled to”
How later courts described this case
- finding that the district court properly denied motion to remand where an employee who had been denied disability benefits by employee benefits plan sought “compensatory damages for money contractually owed Plaintiff, compensation for mental anguish caused by breach of this contract, as well as immediate reimplementation of all benefits and insurance coverages Plaintiff is entitled to”
- stating that “even with” the existence of a cause of action under § 502(a) of ERISA, the Court “would be reluctant to find that extraordinary preemptive power ... that converts an ordinary state common law complaint into one stating a federal claim,” without explicit evidence of congressional intent from the legislative history
- explaining that “[o]ne corollary of the well-pleaded complaint rule developed in the case law, however, is that Congress may so completely pre- empt a particular area that any civil complaint raising this select group of claims is necessarily federal in character”
- holding that 28 U.S.C. § 1331 provides jurisdiction over a suit which involves an ERISA plan, even though the suit purports to raise only state law claims, since the suit is “necessarily federal in character by virtue of the manifest intent of congress.”
Written by the judges who cited it.
Later courts went against this
Reported superseded by statute, as recognized in Hunter v. Ameritech — not on the Supreme Court's list
481 U.S. 58, 65 (1987), superseded by statute on other grounds as stated in, Hunter v. Ameritech, 779 F. Supp. 419, 421
District Court, N.D. IllinoisNov 15, 19915 citing opinionsby statuteother groundsunconfirmed confidenceRead it
The opinion
Justice Brennan,
with whom Justice Marshall joins, concurring.
I write separately only to note that today’s holding is a narrow one. The Court rejects the position, urged by respondent, that removal jurisdiction exists only when the complaint states a claim that is “obviously” pre-empted by state law— that is, when a federal statute has obviously pre-empted state law, or when a decision of this Court has construed an ambiguous federal statute to pre-empt state law. The Court instead focuses on the “intent of Congress,” ante, at 66, to make respondent’s cause of action removable to federal court. This intent to pre-empt became effective when ERISA became law. Consequently, although pre-emption was not obvious under respondent’s standard at the time of removal, * the District Court did in fact have jurisdiction over respondent’s pre-empted claim.
While I join the Court’s opinion, I note that our decision should not be interpreted as adopting a broad rule that any defense premised on congressional intent to pre-empt state law is sufficient to establish removal jurisdiction. The Court holds only that removal jurisdiction exists when, as here, *68 “Congress has clearly manifested an intent to make causes of action . . . removable to federal court” Ibid, (emphasis added). In future cases involving other statutes, the prudent course for a federal court that does not find a clear congressional intent to create removal jurisdiction will be to remand the case to state court.
In the understated words of a prior ease which this Court repeats today, the pre-emption provisions of ERISA “ ‘perhaps are not a model of legislative drafting,’ ” Pilot Life Ins. Co. v. Dedeaux, ante, at 46, quoting Metropolitan Life Ins. Co. v. Massachusetts, 471 U. S. 724, 739 (1985). Accordingly, before today’s decision in- Pilot Life, the answer to the question whether ERISA pre-empted state claims of the sort at issue here was not obvious.