Gobielle v. Liberty Mutual Insurance Company

ERISA pre-empts state law that would otherwise require health insurance providers to report health care claims and other information to a state agency.

A Vermont law requires health insurers to report certain confidential information to the state regarding the cost of the services provided. Included in this mandatory reporting scheme is Blue Cross, a third party administrator for a Respondent’s health plan that is covered under the Employee Retirement Income Security Act of 1974 (ERISA). Blue Cross was ordered to report information under the Vermont reporting law. Respondent instructed Blue Cross to not comply with the reporting law and filed a lawsuit against Vermont in federal court, claiming that the reporting law is pre-empted by ERISA. The District Court granted summary judgment for Vermont and the Court of Appeals for the Second Circuit reversed. The Supreme Court held that the ERISA pre-emption clause is in direct conflict with the Vermont reporting rule. The Court held that the requirements of the Vermont reporting statute are inconsistent with the purpose of ERISA and rejected the contention that the Vermont reporting statute fell outside of the scope of ERISA. The Court further held that reporting the type of information as is required by the Vermont statute goes against one of the main purposes of ERISA. The Vermont reporting statute was in violation with the purposes and duties of ERISA. Affirmed.