Aetna Health, Inc. v. Davila & Cigna Healthcare of Texas v. Calad (consolidated)
Davila and Calad sued their respective health maintenance organizations (HMOs) for negligence under Texas state law, alleging that although their doctors recommended certain treatments, the HMOs negligently refused to cover them. The HMOs removed the cases to federal court, arguing that because each plaintiff received HMO coverage through his or her employer's plan, the claims arose under the Employment Retirement Income Security Act (ERISA). The plaintiffs moved to remand to state court. The district courts denied the remand motions and dismissed the claims, citing preemption under ERISA section 502. The Fifth Circuit Court of Appeals reversed, concluding that section 502 does not preempt Calad or Davila's claims because their HMOs were not acting as plan fiduciaries when denying them medical treatment, and that the suits were properly brought in state court.
Question Presented:
Whether the Employment Retirement Income Security Act (ERISA) ยง 502(a) prevents individuals from filing state lawsuits against their health maintenance organization when the HMO refuses to pay for
recommended treatment.
