Disability claims filed under an ERISA plan are different than disability claims that are not governed by ERISA. The United State District Court, Northern District, Dallas Division, issued an opinion in 2018, that discusses these types of cases. The case is styled, Aaron Rome v. HCC Life Insurance Company.
This is a dispute between a former professional hockey player (Aaron) and his insurer (HCC).
Aaron suffered a career ending injury. He sough benefits under the HCC policy and was denied. Aaron filed suit in State Court including claims for violations of State law and the case was removed to Federal Court where HCC filed motions to have have the State law claims dismissed under Rule 12(b)(6) or in the alternative a motion for summary judgment.
In ruling on a Rule 12(b)(6) motion, a court must generally limit its review to the face of the pleadings. However, the court can consider documents outside the pleading if they fall within certain limited categories. The documents must be referenced or attached to the pleadings, or attached to a motion to dismiss. A court can also rely on matters of public record.
A given policy qualifies as an ERISA Plan if a plan: (1) exists; (2) does not fall within ERISA’s safe harbor provision; and (3) is established or maintained by an employer or employee organization for the benefit of employees. This Plan meets all three requirements.
Pursuant to 29 U.S.C. Section 1144(a) ERISA supersedes state laws. Accordingly, ERISA preempts any state law cause of action brought by an ERISA Plan participant alleging improper processing of a claim for benefits.
Aaron has not plead any action except state law causes of action. Because of this, he has not articulated any facts that would entitle him to relief.
HCC’s Rule 12(b)(6) motion to dismiss was granted.