Metropolitan Life Ins. Co. v. Taylor

481 U. S. 58

April 6, 1987

Arthur Taylor attempted to get disability benefits from Metropolitan Life Insurance, but his employer, General Motors, claimed that he was not disabled. Shortly afterward, General Motors fired Taylor. Taylor brought suit in state court against Metropolitan Life and GM, both for the disability benefits and for wrongful termination. In his complaint he never mentioned ERISA. Nonetheless, Metropolitan Life got the case removed to a federal court, arguing that removal was possible when a state law claim was patently preempted by a federal law. The federal court rejected both the benefits claim under ERISA and the wrongful termination claim under state law. Taylor appealed, arguing that removal never should have occurred given that he did not mention ERISA in his complaint.

O’Connor wrote for a unanimous Court. Although stating a federal claim is usually necessary for removal to federal court, she ruled that removal can be effected if the state law claims have been very thoroughly preempted by a federal law. ERISA was just such a federal law, as Dedeaux had shown. In response to Taylor’s claim that this removal power was not obvious at the time he file his suit, O’Connor said that this did not matter if the intent of Congress was clearly to bring about such preemption. Brennan, joined by Marshall, concurred, but noted that Taylor’s obviousness argument might have some merit if the intent of Congress to preempt were less clear.

I don’t like this ruling either. Even though the federal court was probably correct to deny Taylor’s claims, it was still a dirty trick that got his case removed in the first place. I also hate the notion of forcing lawyers to anticipate what non-obvious doctrinal developments the Supreme Court might make years down the road.

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