United States Third Circuit
Menkes v. Prudential Ins. Co. of Am., 13-1408
In a class action, dismissal of plaintiffs' complaint for failure to state a claim is affirmed, where: 1) plaintiffs' purchased supplemental private insurance in addition to the employer-provided, Employee Retirement Income Security Act (ERISA) benefits plan; 2) the supplemental private insurance was not available without the requisite provision of employer-provided insurance, and therefore, the supplemental insurance could not be unbundled from the basic, employer-provided ERISA benefits plans; 3) plaintiffs' supplemental private insurance were governed by ERISA; and 4) the Court determined that ERISA's expansive pre-emption powers expressly pre-empted plaintiffs' various claims, including but not limited to common law fraud, misrepresentation, breach of contract, breach of fiduciary duty, and punitive damages.
Appellate Information
- Decided 08/06/2014
- Published 08/06/2014
Judges
- Chagares
Court
- United States Third Circuit