Lee v. E.I. DuPont de Nemours and Company

Summary

ERISA preempts state law fraud and misrepresentation claims by former employees seeking increased retirement benefits based on alleged oral misrepresentations about a future plan amendment. The Fifth Circuit held that such claims "relate to" an employee benefit plan under 29 U.S.C. § 1144(a), regardless of whether the misrepresentation concerns existing plan terms or future amendments, and regardless of whether ERISA itself provides a remedy under § 1132(a). The decision affirms the broad preemptive scope of ERISA over state causes of action that interfere with the exclusively federal scheme of pension regulation.

Holdings

1. State law claims for fraud and misrepresentation that relate to an employee benefit plan are preempted by ERISA, regardless of whether the misrepresentation concerns present or future benefits, and even if ERISA itself provides no remedy for the alleged misrepresentation.

Questions Presented

1. Whether the plaintiffs' state law fraud and misrepresentation claims are preempted by the Employee Retirement Income Security Act (ERISA), 29 U.S.C. § 1144(a).

Disposition

affirmed