Robert Cromwell, et al. v. Equicor-Equitable HCA Corp.

Summary

The Sixth Circuit affirmed the district court's decision holding that the plaintiffs' state-law claims arising from alleged assurances of ERISA plan coverage were preempted. The court also held that removal was proper because the complaint asserted a claim arising under ERISA, and that the plaintiffs' eventual lack of ERISA standing did not retroactively defeat federal jurisdiction or require remand. The opinion includes a concurrence and a dissent addressing the proper sequence of jurisdictional and preemption analysis.

Holdings

1. The plaintiffs' promissory-estoppel, breach-of-contract, negligent-misrepresentation, and breach-of-good-faith claims were preempted because they sought recovery of benefits allegedly payable under an ERISA employee benefit plan and therefore related to that plan.
2. The complaint stated a claim arising under ERISA because plaintiffs claimed rights under an assignment of benefits and sought to recover benefits under the Beckman plan; removal to federal court was therefore proper.
3. The plaintiffs' lack of standing under ERISA did not retroactively defeat the district court's removal jurisdiction or require remand of the preempted state-law claims.

Questions Presented

1. Whether the plaintiffs' state-law claims were preempted by ERISA.
2. Whether the plaintiffs' breach-of-contract claim arose under ERISA and supported federal removal jurisdiction.
3. Whether the district court's later determination that the plaintiffs lacked standing under ERISA retroactively defeated removal jurisdiction and required remand of the state-law claims.

Disposition

affirmed