Gobeille v. Liberty Mutual Insurance Company | |
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Argued December 2, 2015 Decided March 1, 2016 | |
Full case name | Alfred Gobeille, in his Official Capacity as Chair of the Vermont Green Mountain Care Board, Petitioner v. Liberty Mutual Insurance Company |
Docket no. | 14–181 |
Citations | 577 U.S. ___ ( more ) 136 S. Ct. 936; 194 L. Ed. 2d 20 |
Opinion announcement | Opinion announcement |
Case history | |
Prior | Liberty Mut. Ins. Co. v. Donegan, 746 F.3d 497 (2d Cir. 2014) |
Court membership | |
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Case opinions | |
Majority | Kennedy, joined by Roberts, Thomas, Breyer, Alito, Kagan |
Concurrence | Thomas |
Concurrence | Breyer |
Dissent | Ginsburg, joined by Sotomayor |
Laws applied | |
Employee Retirement Income Security Act, 29 U.S.C. § 1001 et seq. |
Gobeille v. Liberty Mutual Insurance Company, 577 U.S. ___ (2016), was a United States Supreme Court case in which the Court held that a Vermont state law requiring the disclosure of certain information relating to health care services was preempted by the Employee Retirement Income Security Act (ERISA) to the extent that the state law applied to ERISA plans. [1] Writing for a majority of the Court, Justice Anthony Kennedy held that the Vermont law "impose[d] duties that are inconsistent with the central design of ERISA, which is to provide a single uniform national scheme for the administration of ERISA plans without interference from laws of the several States". [2]
The Employee Retirement Income Security Act of 1974 (ERISA) is a U.S. federal tax and labor law that establishes minimum standards for pension plans in private industry. It contains rules on the federal income tax effects of transactions associated with employee benefit plans. ERISA was enacted to protect the interests of employee benefit plan participants and their beneficiaries by:
John Morrison is an American attorney and politician who served as the elected Montana State Auditor and Insurance and Securities Commissioner from 2001 to 2009. Morrison has been a leader in health insurance policy and litigation and has handled prominent legal cases. He is the senior partner at Morrison Sherwood Wilson Deola, a public interest law firm based in Helena, Montana. In 2006, he ran unsuccessfully against Jon Tester in the Montana Democratic primary for the United States Senate nomination.
Egelhoff v. Egelhoff, 532 U.S. 141 (2001), is a major decision of the Supreme Court of the United States on federalism, specifically with regards to the preemption powers of federal law over state laws. It sets the precedent that any state statutes having a "connection with" ERISA plans are superseded by ERISA, or any future substantially similar law that takes its place. In essence, this decision is a reaffirmation of the right and ability of the federal government to, at least in some instances, pre-empt state laws.
Rush Prudential HMO, Inc. v. Moran, 536 U.S. 355 (2002), was a decision by the Supreme Court of the United States, which ruled that the federal Employee Retirement Income Security Act (ERISA) did not preempt an Illinois medical-review statute.
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Aetna Health Inc. v. Davila, 542 U.S. 200 (2004), was a United States Supreme Court case in which the Court limited the scope of the Texas Healthcare Liability Act (THCLA). The effective result of this decision was that the THCLA, which held Case Management and Utilization Review decisions by Managed Care entities like CIGNA and Aetna to a legal duty of care according to the laws of The State of Texas could not be enforced in the case of Health Benefit plans provided through private employers, because the Texas statute allowed compensatory or punitive damages to redress losses or deter future transgressions, which were not available under ERISA § 1132. The ruling still allows the State of Texas to enforce the THCLA in the case of Government-sponsored (Medicare, Medicaid, Federal, State, Municipal Employee, etc., Church-sponsored, or Individual Health Plan Policies, which are saved from preemption by ERISA. The history that allows these Private and Self-Pay Insurance to be saved dates to the "Interstate Commerce" power that was given the federal Government by the Supreme Court. ERISA, enacted in 1974, relied on the "Interstate Commerce" rule to allow federal jurisdiction over private employers, based on the need of private employers to follow a single set of paperwork and rules for pensions and other employee benefit plans where employers had employees in multiple states. Except for private employer plans, insurance can be regulated by the individual states, and Managed Care entities making medical decisions can be held accountable for those decisions if negligence is involved, as allowed by the Texas Healthcare Liability Act.
Stop the Beach Renourishment v. Florida Department of Environmental Protection, 560 U.S. 702 (2010), was a United States Supreme Court case in which the Court held that the Florida Supreme Court did not effect an unconstitutional taking of littoral property owners' rights to future accretions and to contact the water by upholding Florida's beach renourishment program.
Obergefell v. Hodges, 576 U.S. 644 (2015), is a landmark decision of the Supreme Court of the United States which ruled that the fundamental right to marry is guaranteed to same-sex couples by both the Due Process Clause and the Equal Protection Clause of the Fourteenth Amendment of the Constitution. The 5–4 ruling requires all fifty states, the District of Columbia, and the Insular Areas to perform and recognize the marriages of same-sex couples on the same terms and conditions as the marriages of opposite-sex couples, with all the accompanying rights and responsibilities. Prior to Obergefell, same-sex marriage had already been established by statute, court ruling, or voter initiative in thirty-six states, the District of Columbia, and Guam.
Mullenix v. Luna, 577 U.S. ___ (2015), was a case in which the Supreme Court of the United States held that a police officer who shot a suspect during a police pursuit was entitled to qualified immunity. In a per curiam opinion, the Court held that prior precedent did not establish "beyond debate" that the officer's actions were objectively unreasonable.
OBB Personenverkehr AG v. Sachs, 577 U.S. ___ (2015), is a decision by the Supreme Court of the United States, holding that the Foreign Sovereign Immunities Act barred a California resident from bringing suit against an Austrian railroad in federal district court. The case arose after a California resident suffered traumatic personal injuries while attempting to board a train in Innsbruck, Austria. She then filed a lawsuit against the railroad in the United States District Court for the Northern District of California in which she alleged the railroad was responsible for causing her injuries. Because the railroad was owned by the Austrian government, the railroad claimed that the lawsuit should be barred by the Foreign Sovereign Immunities Act, which provides immunity to foreign sovereigns in tort suits filed in the United States. In response, the plaintiff argued that her suit should be permitted under the Foreign Sovereign Immunity Act's commercial activity exception because she purchased her rail ticket in the United States.
DIRECTV, Inc. v. Imburgia, 577 U.S. ___ (2015), was a case in which the Supreme Court of the United States clarified when arbitration provisions in contracts are governed by the Federal Arbitration Act. In a 6–3 opinion written by Justice Stephen Breyer, the Court reversed a decision by the California Court of Appeal that refused to enforce an arbitration agreement between DIRECTV and its customers. The California Court had ruled that the arbitration agreement was unenforceable because, under applicable California law, a class action arbitration waiver between DIRECTV and its customers was unenforceable. However, the Supreme Court of the United States held that the California Court of Appeal's interpretation was preempted by the Federal Arbitration Act, and the California Court of Appeal was therefore required to enforce the arbitration agreement.
Kansas v. Carr, 577 U.S. 108 (2016), was a case in which the Supreme Court of the United States clarified several procedures for sentencing defendants in capital cases. Specifically, the Court held that judges are not required to affirmatively instruct juries about the burden of proof for establishing mitigating evidence, and that joint trials of capital defendants "are often preferable when the joined defendants’ criminal conduct arises out of a single chain of events". This case included the last majority opinion written by Justice Antonin Scalia before his death in February 2016.
Montanile v. Board of Trustees of the National Elevator Industry Health Benefit Plan, 577 U.S. ___ (2016), was a case in which the Supreme Court of the United States clarified subrogation procedures under the Employee Retirement Income Security Act ("ERISA"). The Court held that healthcare plan fiduciaries cannot demand reimbursement for medical benefits from a plan member's general assets if the beneficiary's general assets cannot be traced back to the original payment from the fiduciary. Although some scholars suggested that the court's ruling would have little impact, others suggested the case places "significant restrictions" on the rights of ERISA benefit plan providers.
Caetano v. Massachusetts, 577 U.S. 411 (2016), was a case in which the Supreme Court of the United States unanimously vacated a Massachusetts conviction of a woman who carried a stun gun for self-defense.
Zubik v. Burwell, 578 U.S. ___ (2016), was a case before the United States Supreme Court on whether religious institutions other than churches should be exempt from the contraceptive mandate, a regulation adopted by the United States Department of Health and Human Services (HHS) under the Affordable Care Act (ACA) that requires non-church employers to cover certain contraceptives for their female employees. Churches are already exempt under those regulations. On May 16, 2016, the Supreme Court vacated the Court of Appeals ruling in Zubik v. Burwell and the six cases it had consolidated under that title and returned them to their respective courts of appeals for reconsideration.
Bank Markazi v. Peterson, 578 U.S. 212 (2016), was a United States Supreme Court case that found that a law which only applied to a specific case, identified by docket number, and eliminated all of the defenses one party had raised does not violate the separation of powers in the United States Constitution between the legislative (Congress) and judicial branches of government. The plaintiffs, in the case had initially obtained judgments against Iran for its role in supporting state-sponsored terrorism, particularly the 1983 Beirut barracks bombings and 1996 Khobar Towers bombing, and sought execution against a bank account in New York held, through European intermediaries, on behalf of Bank Markazi, the Central Bank of the Islamic Republic of Iran. The plaintiffs obtained court orders preventing the transfer of funds from the account in 2008 and initiated their lawsuit in 2010. Bank Markazi raised several defenses, including that the account was not an asset of the bank, but rather an asset of its European intermediary, under both New York state property law and §201(a) of the Terrorism Risk Insurance Act. In response to concerns that existing laws were insufficient for the account to be used to settle the judgments, Congress added an amendment to a 2012 bill, codified after enactment as 22 U.S.C. § 8772, that identified the pending lawsuit by docket number, applied only to the assets in the identified case, and effectively abrogated every legal basis available to Bank Markazi to prevent the plaintiffs from executing their claims against the account. Bank Markazi then argued that § 8772 was an unconstitutional breach of the separation of power between the legislative and judicial branches of government, because it effectively directed a particular result in a single case without changing the generally applicable law. The United States District Court for the Southern District of New York and, on appeal, the United States Court of Appeals for the Second Circuit both upheld the constitutionality of § 8772 and cleared the way for the plaintiffs to execute their judgments against the account, which held about $1.75 billion in cash.
Campbell-Ewald Co. v. Gomez, 577 U.S. 153 (2016), was a case in which the Supreme Court of the United States clarified whether a case becomes moot when a party provides a settlement offer that satisfies a named plaintiff's claims in a class action suit and whether a government contractor is entitled to "derivative sovereign immunity".
Americold Realty Trust v. ConAgra Foods, Inc., 577 U.S. ___ (2016), was a case in which the Supreme Court of the United States clarified rules for determining whether a federal court may exercise diversity jurisdiction in cases involving unincorporated organizations. The case began as a contract dispute between food producers and a warehouse owner when millions of tons of stored food were destroyed in a warehouse fire. A federal trial court initially ruled in favor of the warehouse owner, but on appeal, the United States Court of Appeals for the Tenth Circuit ruled that the federal district court may not have had jurisdiction. The Tenth Circuit held that the warehouse owner, a real estate investment trust ("REIT"), should be treated as an unincorporated organization and the district court should not be allowed to exercise diversity jurisdiction without examining the citizenship of the members of the real estate investment trust. The warehouse owner appealed to the Supreme Court, which granted certiorari to resolve a circuit split "regarding the citizenship of unincorporated entities."
Sturgeon v. Frost refers to two cases heard by the Supreme Court of the United States, both of which deal with the regulatory authority of the National Park Service over lands in Alaska under the Alaska National Interest Lands Conservation Act (ANILCA). In the first case, Sturgeon v. Frost I, 577 U.S. ___ (2016), the Court ruled that the National Park Service may regulate only "public" lands in Alaska and remanded the case to the Ninth Circuit Appeals Court to decide whether the river in question, which is "submerged land," is "public" or "non-public" land. In Sturgeon v. Frost II, 587 U.S. ___ (2019), the Court unanimously ruled that the ANILCA defines navigable waters in Alaska as "non-public" lands and that they are exempt from the National Park Service's national regulations.
State Farm Fire & Casualty Co. v. United States ex rel. Rigsby, 580 U.S. ___ (2016), was a case in which the Supreme Court of the United States clarified the consequences of violating the False Claims Act's requirement that cases be kept under seal. In a unanimous opinion written by Justice Anthony Kennedy, the Court held that a violation of the False Claim Act's seal requirement does not require the dismissal of a complaint.