Wednesday, November 13, 2013

Retail Industry Leaders Association v. Fielder case brief

Retail Industry Leaders Association v. Fielder case brief summary
475 F.3d 180 (2007)

Appellee trade association sued appellant state secretary of labor, seeking to enjoin enforcement of the Fair Share Health Care Fund Act, Md. Code Ann., Lab. & Empl. § 8.5-101 to -107 (the Act), as preempted by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C.S. § 1144(a). The United States District Court for the District of Maryland granted summary judgment in favor of the association, and the government sought review.


The Act required employers with 10,000 or more Maryland employees to spend at least eight % of their total payroll on employees' health insurance costs or pay the amount their spending fell short to the state. Only one employer in the state was subject to this minimum spending requirement.


  • On appeal, the court rejected the government's jurisdictional challenges, finding that the association had standing to sue and that the lawsuit was ripe for adjudication. 
  • In addition, the Tax Injunction Act, 28 U.S.C.S. § 1341, did not bar the suit because the Act constituted health care regulation, rather than a tax. 
  • On the merits, the court agreed with the district court that the Act was preempted by ERISA. 
  • The only rational choice for employers under the Act was to structure their ERISA health care benefit plans to meet the minimum spending threshold. 
  • Because the Act effectively mandated that employers structure their employee health care plans to provide a certain level of benefits, the Act had an obvious "connection with" employee benefit plans, and it was preempted by ERISA. 
  • Accordingly, the court upheld the district court's ruling granting summary judgment in favor of the association.


The court affirmed the district court's decision.

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