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Supreme Court· 6/20/2002

Rush Prudential HMO, Inc. v. Moran

Citations

  • 536 U.S. 355
  • 122 S. Ct. 2151
  • 153 L. Ed. 2d 375
  • 2002 U.S. LEXIS 4644

About this case

Rush Prudential HMO, Inc. v. Moran

Rush Prudential HMO, Inc. v. Moran, 536 U.S. 355 (2002), was a decision by the Supreme Court of the United States in which the court held that the federal Employee Retirement Income Security Act (ERISA) did not preempt an Illinois medical-review statute.[_clarification needed
_][1] [2] [3]

ERISA envisions a national standard for welfare and pension plans so state laws which "relate to" ERISA plans are preempted under Section 514 of ERISA. However, ERISA contains a "savings" clause which saves state laws which regulate insurance under Section 514(b). The statute at issue in Moran regulated insurance, which is one of the functions HMOs perform. Although HMOs provide healthcare as well as insurance, the statute does not require choosing a single or primary function of an HMO . Congress has long recognized that HMOs are risk-bearing organizations subject to state regulation. Finally, allowing States to regulate the insurance aspects of HMOs will not interfere with the desire of Congress for uniform national standards under ERISA .

This case was partially overruled in _Kentucky Ass'n of Health Plans, Inc. v. Miller _, 538 U.S. 329 (2003).

References

(https://en.wikipedia.org/w/index.php?title=Rush_Prudential_HMO,_Inc._v._Moran&action=edit&section=1 "Edit section: References")

  1. ↑ Rush Prudential HMO, Inc. v. Moran, 536 U.S. 355 (2002).
  2. ↑ Reinhart, Stephanie (January 1, 2004). "Rush Prudential HMO, Inc. v. Moran: 21 or Bust! Does ERISA Preemption Give HMOs the Power to Gamble with Our Health?" . Akron Tax Journal. 19 (1). ISSN  0002-371X .
  3. ↑ Berman-Sandler, Leatrice (January 1, 2004). "Independent Medical Review: Expanding Legal Remedies to Achieve Managed Care Accountability" . Annals of Health Law and Life Sciences. 13 (1): 233. ISSN  1075-2994 .

External links

(https://en.wikipedia.org/w/index.php?title=Rush_Prudential_HMO,_Inc._v._Moran&action=edit&section=2 "Edit section: External links")

Retrieved from "https://en.wikipedia.org/w/index.php?title=Rush_Prudential_HMO,_Inc._v._Moran&oldid=1355911477 "

Editorial context from Wikipedia (CC-BY-SA 4.0).

How courts have described this case

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

  • holding that because HMOs spread risk in the manner of insurers, independent-review provisions are saved from preemption
  • recognizing that \a state regulatory scheme that provides no new cause of action under state law and authorizes no new form of ultimate relief\ is not preempted
  • holding that Illinois statute requiring HMOs to provide independent medical review of certain claim denials is saved from preemption because the statute regulates insurance within the meaning of ERISA’s savings clause
  • holding that the possibility that a state law could affect non-insurers is not enough “to remove a state law entirely from the category of insurance regulation saved from preemption”
  • holding that because HMOs spread risk in the manner of insurers, independent-review provisions are saved from preemption
  • holding that savings clause allowed Illinois to enforce law requiring independent medical review of certain denials of medical benefits

Source: CourtListener parenthetical corpus (CC0).

Judges: Souter, Stevens, O'Connor, Ginsburg, Breyer, Thomas, Rehnquist, Scaua, Kennedy

Read full opinion on CourtListener

Cited by

219 cases in this archive cite this case; the 20 most cited are listed.

Cites

38 cases in this archive are cited by this case; the 20 most cited are listed.

Other cases named Rush Prudential HMO, Inc. v. Moran

5 other CourtListener records share this case name.

Sourced from CourtListener / Free Law Project (CC0).

This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.