481 U. S. 41
April 6, 1987
Everate Dedeaux was disabled in a work-related accident. Pilot Life Insurance took care of disability benefits at the company Dedeaux worked at. Over the next several years though, Pilot Life would alternately pay and cut off these benefits to Dedeaux. Accordingly, he sued Pilot Life using state common law claims. Pilot Life responded that these claims were preempted by the Employee Retirement Income Security Act (ERISA).
O’Connor wrote for a unanimous Court, which held that ERISA did preempt the common law claims Dedeaux had filed. ERISA expressly preempted all state laws that related to benefits plans, with an exception only for a law “which regulates insurance.” Although the common law claims that Dedeaux filed had been held applicable against insurance companies many times, they had not been originally created as a means of targeting or regulating the insurance industry. Thus, they were preempted. O’Connor proceeded to spend more pages than necessary proving that the legislative history of ERISA clearly established an intention to preempt almost everything.
On its face, I agree that ERISA did preempt the claims Dedeaux filed. But this is one of those cases where I wished the Supreme Court had examined the Constitutionality of the federal law. ERISA strikes me as one of those laws that is completely beyond the enumerated powers of Congress listed in Article I. I’ve felt the same way about other federal laws that have been addressed in preemption cases. As with so many other Constitutional battles though, my side probably lost the debate permanently back in the 1930s.