Chesapeake & O. Ry. Co. v. Lash's Adm'r

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that federal jurisdiction existed for a claim over which the district court could have, but did not explicitly, invoke supplemental jurisdiction
• concluding that § 1132(a) only allows suits for legal relief against ERISA plans, administrators, or fiduciaries
• holding that a negligence claim against an HMO utilization review case manager was completely preempted because the claim was “in effect a claim for denial of benefits”
• explaining that the “ ‘complete preemption doctrine’ is actually a misnomer because it is not a preemption doctrine but, rather, a federal jurisdiction doctrine”
• reasoning that complete preemption “converts a state law claim into an action arising under federal law”
• stating that “[t]he claim was nonetheless properly dismissed because Jass sued Margulis in an individual capacity and ‘ERISA permits suits to recover benefits only against the Plan as an entity.’ ”

Source: CourtListener parenthetical corpus (CC0).