In Home Health, Inc. v. The Prudential Insurance Company of America

How courts have described this case

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

• holding that state claim did not negate ERISA plan provisions where plaintiffs did not seek plan benefits or challenge the plan’s structure
• holding that ERISA did not preempt third-party health care provider’s negligent misrepresentation claim against administrator of employee benefit plan where provider was not suing in its capacity as an assignee of an ERISA beneficiary
• stating that a state claim is less likely to be preempted “if it affects relations between [a primary ERISA entity] and an outside party” (internal quotations and citation omitted)
• finding that ERISA did not preempt state tort claims by a third-party provider against an ERISA plan administrator, where the third-party provider sued “not as an assignee of an ERISA beneficiary but as an independent entity claiming damages.”
• observing that where allowing a party to proceed with state-law claims “would not impose any additional administrative duties upon [a plan administrator] or require a change in administrative procedures[,]” the third Ark. BCBS factor did not weigh in favor of preemption
• \Allowing Home Health to proceed with its claim for negligent misrepresentation would not impose any additional administrative duties upon Prudential or require a change in administrative procedures.\

Source: CourtListener parenthetical corpus (CC0).