ERISA-Fifth Circuit Determines That ERISA Preempts State Law Claim That Participant Was Not Married

In Blake v. Metropolitan Life Insurance Company, No. 10-40736 (Fifth Circuit 2011), the Court faced the issue of whether ERISA preempts a state law claim that a plan participant was not married.

In this case, the plaintiffs’ father was covered under a life and accident plan at work (the “Plan”). The Plan was subject to ERISA, and its benefits were insured by the defendant, Metropolitan Life Insurance Company (“Metropolitan”). When the plaintiff’s father died, a death benefit became payable under the Plan. But to whom? The Plan provided that the death benefit would be paid to the covered individual’s spouse, or if none, to his children. At the time of his death, the father was residing with a woman that he had earlier divorced. Metropolitan determined that the father and this woman were married, and paid the death benefit to the woman. The plaintiff’s then filed this suit, seeking a declaration that under state law, the father and this woman were not married at the time the father died.

The Court concluded that the plaintiff’s state law claim is preempted by ERISA. This obtains because the determination of marital status did not arise from any matter which is separate from the determination of who is entitled to the death benefit under the Plan, and this suit could have been brought under § 502(a) of ERISA to collect that benefit.

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