Wiley Blount Rutledge Jr. was an American jurist who served as an associate justice of the Supreme Court of the United States from 1943 to 1949. The ninth and final justice appointed by President Franklin D. Roosevelt, he is best known for his impassioned defenses of civil liberties. Rutledge favored broad interpretations of the First Amendment, the Due Process Clause, and the Equal Protection Clause, and he argued that the Bill of Rights applied in its totality to the states. He participated in several noteworthy cases involving the intersection of individual freedoms and the government's wartime powers. Rutledge served on the Court until his death at the age of fifty-five. Legal scholars have generally thought highly of the justice, although the brevity of his tenure has minimized his impact on history.
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:
The Pension Benefit Guaranty Corporation (PBGC) is a United States federally chartered corporation created by the Employee Retirement Income Security Act of 1974 (ERISA) to encourage the continuation and maintenance of voluntary private defined benefit pension plans, provide timely and uninterrupted payment of pension benefits, and keep pension insurance premiums at the lowest level necessary to carry out its operations. Subject to other statutory limitations, PBGC's single-employer insurance program pays pension benefits up to the maximum guaranteed benefit set by law to participants who retire at 65. The benefits payable to insured retirees who start their benefits at ages other than 65 or elect survivor coverage are adjusted to be equivalent in value. The maximum monthly guarantee for the multiemployer program is far lower and more complicated.
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.
An independent medical review (IMR) is the process where physicians review medical cases in order to provide claims determinations for health insurance payers, workers compensation insurance payers or disability insurance payers. Peer review also is used in order to define the review of sentinel events in a hospital environment for quality management purposes such as to look at bad outcomes and determine whether there was any mis-diagnosis, mistreatment or any systemic problems involved which led to the sentinel event.
Utilization management (UM) or utilization review is the use of managed care techniques such as prior authorization that allow payers, particularly health insurance companies, to manage the cost of health care benefits by assessing its medical appropriateness before it is provided, by using evidence-based criteria or guidelines.
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.
IQVIA, formerly Quintiles and IMS Health, Inc., is an American Fortune 500 and S&P 500 multinational company serving the combined industries of health information technology and clinical research. IQVIA is a provider of biopharmaceutical development, professional consulting and commercial outsourcing services, focused primarily on Phase I-IV clinical trials and associated laboratory and analytical services, including investment strategy and management consulting services. It has a network of more than 88,000 employees in more than 100 countries and a market capitalization of US$49 billion as of August 2021. As of 2023, IQVIA was reported to be one of the world's largest contract research organizations (CRO).
Mertens v. Hewitt Associates, 508 U.S. 248 (1993), is the second in the trilogy of United States Supreme Court ERISA preemption cases that effectively denies any remedy for employees who are harmed by medical malpractice or other bad acts of their health plan if they receive their health care from their employer.
The Employee Benefits Security Administration (EBSA) is an agency of the United States Department of Labor responsible for administering, regulating and enforcing the provisions of Title I of the Employee Retirement Income Security Act of 1974 (ERISA). At the time of its name change in February 2003, EBSA was known as the Pension and Welfare Benefits Administration (PWBA). Prior to January 1986, PWBA was known as the Pension and Welfare Benefits Program. Originally the Program was established as an Office within the Labor Management Services Administration reporting the then Assistant Secretary Paul Fasser and his successors from 1974 through 1986.
In the United States, a pharmacy benefit manager (PBM) is a third-party administrator of prescription drug programs for commercial health plans, self-insured employer plans, Medicare Part D plans, the Federal Employees Health Benefits Program, and state government employee plans. PBMs operate inside of integrated healthcare systems, as part of retail pharmacies, and as part of insurance companies.
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.
John Rutledge Jr. was an American Founding Father, politician, and jurist who served as one of the original associate justices of the Supreme Court and the second chief justice of the United States. Additionally, he served as the first president of South Carolina and later as its first governor after the Declaration of Independence was signed.
Leslie Carol Rutledge is an American attorney and politician who has served as the 21st lieutenant governor of Arkansas since 2023. A member of the Republican Party, she was previously the 56th attorney general of Arkansas from 2015 to 2023.
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.
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. 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".
Ingersoll-Rand Co. v. McClendon, 498 U.S. 133 (1990), is a US labor law case, concerning the scope of labor rights in the United States.
Fifth Third Bancorp v. Dudenhoeffer, 573 U.S. 409 (2014), was a United States Supreme Court case in which the court found Employee stockownership (ESOP) fiduciaries have the same prudential duties as non-ESOP fiduciaries, as set by ERISA, except that they are not required to diversify their investments beyond shares of the employer's stock.
The Supreme Court of the United States handed down fourteen per curiam opinions during its 2020 term, which began October 5, 2020 and concluded October 3, 2021.
