Employee Retirement Income Security Act (ERISA) preemption; ERISA’s civil enforcement provision (29 USC § 1132(a)); Whether plaintiff’s state-law claims were “completely preempted” by ERISA; Aetna Health Inc v Davila; Whether plaintiff complained about the denial of benefits based on the employee benefit plan’s terms; Whether the claims implicated a duty that was “independent of ERISA or the plan terms”; A district court’s discretion to dismiss duplicative cases

In this putative state law claims class action removed to federal court, the court held that the district court did not abuse its discretion by dismissing plaintiff-Patterson’s state claims where they were completely preempted by ERISA. Patterson’s employer maintained an ERISA health plan through defendant-UnitedHealth. The case arose after Patterson incurred medical bills due to a car accident. United paid the bills and sought to recover the payments he received through a suit against the involved third-party. An agreement settled that dispute. But after Patterson’s wife was injured in a separate accident and discovery revealed a plan document that said nothing “about a reimbursement obligation on the Pattersons’ part[,]” Patterson sued United and others under ERISA’s civil enforcement provision, claiming that they defrauded him by requiring him to reimburse them $25,000. That case remains before the district court on remand. While that federal action was pending on appeal, Patterson filed claims in state court alleging fraudulent and negligent misrepresentation, conversion, civil conspiracy, and unjust enrichment. Defendants removed the case to federal court and sought dismissal. The district court agreed with them that the state law claims were a “repackaged version of his still-pending ERISA lawsuit[,]” and were preempted by ERISA. On appeal, the court held that both prongs of Davila were met here. It noted that while it had not yet addressed a case on-all-fours with this one, several other circuits have done so and concluded that “similar state law challenges to an ERISA plan’s reimbursement rights are in essence disguised suits ‘to recover benefits due’ under § 1132(a)(1)(B).” Patterson not only could “have brought a § 1132(a)(1)(B) claim, but in fact he also did bring one, albeit in his first federal lawsuit. There, [he] leveled the same core accusation that he levels here—that defendants tricked him into paying reimbursement using a misleading plan summary. This reality only reinforces the conclusion that [his] state claims double as an ERISA claim ‘to recover benefits due to him’ under § 1132(a)(1)(B).” The court also held that the second Davila prong was met where Patterson’s claims failed to “implicate a duty ‘independent of ERISA or the plan terms.’ . . . Each of defendants’ alleged breaches of duty rests entirely upon what Patterson’s ERISA-governed plan does (or does not) say.” Lastly, it held that the district court did not abuse its discretion by dismissing the case. Affirmed.