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Metropolitan Life Insurance Co. v. Taylor

• 1986 • 481 U.S. 58 • Rehnquist Court
In the case of Metropolitan Life Insurance Co. v. Taylor, 1986, the U.S Supreme Court held that federal law preempted state law claims in relation to an employee benefit plan dispute. The plaintiff, Mr. Taylor was a former employee of United Technologies Corporation (UTC) who had been receiving disability benefits from UTC's insurance carrier, Metropolitan Life Insurance Company (MetLife). After MetLife stopped his payments on grounds that he was no longer disabled under their policy terms,...Open Case
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Chief Rehnquist Court
Term: 1986
Docket: 85-686
481 U.S. 58
107 S. Ct. 1542
95 L. Ed. 2d 55
1987 U.S. LEXIS 1514
Argued: Jan 21, 1987

Metropolitan Life Insurance Co. v. Taylor

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Opinion Summary
AI Abstract

In the case of Metropolitan Life Insurance Co. v. Taylor, 1986, the U.S Supreme Court held that federal law preempted state law claims in relation to an employee benefit plan dispute. The plaintiff, Mr. Taylor was a former employee of United Technologies Corporation (UTC) who had been receiving disability benefits from UTC's insurance carrier, Metropolitan Life Insurance Company (MetLife). After MetLife stopped his payments on grounds that he was no longer disabled under their policy terms, Taylor sued both companies in Michigan state court for wrongful termination of benefits and breach of contract among other charges. However, the defendants successfully petitioned to have the case moved to federal court arguing it fell under Employee Retirement Income Security Act (ERISA), a federal statute governing most private sector employee benefit plans disputes which preempts any related state laws or regulations. The Supreme Court agreed with this argument stating ERISA provided exclusive remedies for such cases thereby superseding any relevant state laws including those invoked by Taylor’s lawsuit against MetLife and UTC.

Dissent Summary
AI Abstract

In the dissenting opinion for Metropolitan Life Insurance Co. v. Taylor, Justice Brennan argued that the majority's decision to preempt state law claims under Section 301 of the Labor Management Relations Act (LMRA) was a misinterpretation of Congressional intent and an overreach by federal courts into areas traditionally governed by state law. He contended that Congress did not intend for Section 301 to completely displace all related state laws when it enacted ERISA, but rather intended to provide a uniform regulatory scheme for employee benefit plans while preserving certain aspects of traditional state regulation in this area. Furthermore, he expressed concern about how preemption would affect employees' rights and protections under their respective states’ laws which may be more favorable than those provided under federal law.

Opinion written by Justice SDOConnor
Decided: Apr 06, 1987
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