Aetna Health, Inc. v. Davila case brief

Aetna Health, Inc. v. Davila case brief summary
542 U.S. 200 (2004)

CASE SYNOPSIS

Respondents, a participant and a beneficiary, sued petitioner health maintenance organizations (HMOs) for alleged failures to exercise ordinary care in the handling of coverage decisions. The cases were removed to federal court based upon Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C.S. § 1001 et seq., preemption. The United States Court of Appeals for the Fifth Circuit rejected the preemption argument. Certiorari was granted.

CASE FACTS
Respondents both suffered injuries allegedly arising from the HMOs' decisions not to provide coverage under ERISA-regulated benefit plans for certain treatment and services recommended by respondents' treating physicians. Respondents alleged that the HMOs failed to exercise ordinary care in the handling of coverage decisions, in violation of a duty imposed by the Texas Health Care Liability Act (THCLA), Tex. Civ. Prac. & Rem. Code Ann. §§ 88.001-88.003 (2004 Supp. Pamphlet).

DISCUSSION

• The United States Supreme Court determined that respondents' causes of action fell within the scope of, and were completely preempted by, ERISA § 502(a)(1)(B), 29 U.S.C.S. § 1132(a)(1)(B), and thus were removable to federal district court under 28 U.S.C.S. § 1441(a), because respondents sued only to rectify wrongful denials of benefits promised under the terms of ERISA-regulated employee benefit plans. 
• The duties imposed by the THCLA in the context of respondents' cases did not arise independently of ERISA or the plan terms. 
• Also, the statutes did not save the causes of action from preemption.

CONCLUSION
The United States Supreme Court reversed the judgment of the appellate court and remanded the cases for further proceedings.

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