In Van Arsdel v. Liberty Life Assurance Company of Boston, the court found that ERISA pre-empted the plaintiff’s state law bad faith claims, whether brought under Pennsylvania or Georgia law. The bad faith claim was related to the alleged denial of benefits under the disability policy at issue, which was an ERISA plan. The court cited numerous examples of ERISA pre-empting Pennsylvania statutory bad faith claims.
Dated of Decision: March 29, 2016
Van Arsdel v. Liberty Life Assur. Co. of Boston, No. 14-2579, 2016 U.S. Dist. LEXIS 40909 (E.D. Pa. Mar. 29, 2016) (Smith, J.)