Supreme Court Endorses Broad ERISA Preemption of Pure Eligibility Determinations by Plan Administrator; Federal Court the Exclusive Forum for Such Claims; Overlapping State Law Causes of Action Not Permitted (original) (raw)

Journal of Risk and Insurance, 2004

Abstract

Aetna Health, Inc. v. Davila, 124 S. Ct. 2488, 159 L.Ed. 2d 312, 72 U.S.L.W. 4516, 2004 U.S. LEXIS 4571 (United States Supreme Court--March 23, 2004) Juan Davila was a participant in an employer-provided benefit plan subject to ERISA (the Employee Retirement Income Security Act of 1974) and Ruby Calad was a beneficiary under another such plan. Under the terms of Davila's plan, administered by Aetna Health, Inc. (formerly Aetna U.S. Healthcare), requests for coverage and payment to health-care providers are reviewed by Aetna. Cigna Healthcare of Texas provided similar administration of Calad's plan. Davila experienced arthritis pain. His treating physician prescribed Vioxx. Aetna refused to pay for reasons not stated in the Court's opinion but presumably because Vioxx was not a prescription medication included in the plan's coverage for arthritis. Davila did not contest or appeal this decision and did not buy Vioxx on his own. Instead, he purchased Naprosyn, "fro...

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