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02-1845 AETNA HEALTH INC. v. DAVILA Ruling below: CA 5, 307 F.3d 298. QUESTION PRESENTED: Whether the Employee Retirement Income Security Act of 1974, 29 U.S.C. §§ 1001 et seq. ("ERISA"), as construed by this Court in Pilot Life Insurance Co. v. Dedeaux, 481 U.S. 41 (1987), and its progeny, completely preempts state-law claims by ERISA plan participants or beneficiaries who assert that a managed care company tortiously "failed to cover" (i.e., pay for) medical care. 03-83 CIGNA HEALTHCARE OF TEXAS v. CALAD Ruling below: CA 5, 307 F.3d 298. QUESTION PRESENTED: Whether § 502(a) of the Employee Retirement Income Security Act of 1974 ("ERISA"), 29U.S.C. § 1132(a), completely preempts a state-law tort claim seeking damages for an allegedly erroneous determination of entitlement to a benefit under an ERISA-governed health benefit plan when the determination is based in part on the exercise of medical judgment. CERT. GRANTED: 11/3/03 Consolidated for one hour oral argument.
The U.S. Supreme Court case Aetna Health Inc., FKA Aetna U.S. Healthcare Inc. and Aetna U.S. Healthcare of North Texas Inc v Juan Davila, 2003 revolved around the issue of whether state law claims against health maintenance organizations (HMOs) were preempted by federal law under the Employee Retirement Income Security Act (ERISA). The plaintiff, Juan Davila, alleged that he suffered severe injuries due to a denial of coverage for certain medications by his HMOs - one being operated by AETNA HEALTH INC., and sought damages under Texas' Health Care Liability Act (THCLA). However, the defendants argued that ERISA preempts such state-law claims because they relate to an employee benefit plan covered by ERISA. The Supreme Court ruled in favor of the defendant holding that ERISA does indeed preempt THCLA as it relates to decisions made about benefits under an employer-sponsored healthcare plan.
In the dissenting opinion for AETNA HEALTH INC., FKA AETNA U.S. HEALTHCARE INC. AND AETNA U.S. HEALTHCARE OF NORTH TEXAS INC. v. JUAN DAVILA, 2003, Justice Ruth Bader Ginsburg argued that state law should not be preempted by federal law in this case because it does not conflict with the objectives of Congress when they enacted ERISA (Employee Retirement Income Security Act). She contended that Texas' Health Care Liability Act provides a remedy to patients who have been harmed by wrongful denial of benefits and doesn't interfere with uniform national administration of employee benefit plans as feared by majority's interpretation of ERISA preemption clause. Furthermore, she expressed concern over limiting patient protection rights and leaving them without adequate recourse against insurers making medical decisions based on cost rather than health needs.