ERISA-Fifth Circuit Rules That Plaintiff/Hospital Has Sufficiently Pleaded Its Claims For ERISA Plan Benefits And State-Law Breach Of Contract

In Innova Hospital San Antonio, Limited Partnership v. BlueCross and Blue Shield of Georgia, Incorporated, No. 14-11300 (5th Cir. 2018), a hospital in San Antonio brought various claims against insurance companies and third-party plan administrators for violations of ERISA. The district court dismissed all of the hospital’s claims except for the claim for attorneys’ fees.

Upon reviewing the case, the Fifth Circuit Court of Appeals (the “Court”) held that the hospital sufficiently pleaded its claims for ERISA plan benefits and state-law breach of contract. The Court reversed the district court’s judgment dismissing these claims and remanded the case to the district court to consider these two claims, as well as the claim for attorneys’ fees. The Court affirmed the district court’s judgment dismissing the hospital’s ERISA claims under 29 U.S.C. § 1132(a)(3) (claims for equitable relief), as well as the district court’s judgment denying leave to amend the complaint out of time.

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