Irene Jones v. LMR International

How courts have described this case

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

• recognizing that the district court had jurisdiction to dismiss claims as conflict preempted because it had supplemental jurisdiction derived from other completely preempted claims
• distinguishing Morstein because the plaintiffs here had admitted that Great West was at one point an ERISA fiduciary
• “A state law claim is defensively preempted under ERISA if it relates to an ERISA plan.”
• “As ERISA claims are completely preempted, ... state law claims that seek relief available under ERISA are recharacterized as ERISA claims and arise under federal law.”
• “Unlike complete preemption, which is jurisdictional, defensive preemption is a substantive defense, justifying dismissal of preempted state law claims.”
• “In reviewing matters concerning removal and remand, ‘it is axiomatic that ambiguities are generally construed against removal.’” (quoting Butler v. Polk, 592 F.2d 1293, 1296 (5th Cir. 1979))

Source: CourtListener parenthetical corpus (CC0).