FEBRUARY 2006 BAD FAITH CASES DISABILITY INSURANCE BAD FAITH CLAIM PRE-EMPTED BY ERISA (Philadelphia Federal)

In McBride v. Hartford Life & Accident Insurance Company, the U.S. District Court for the Eastern District of Pennsylvania held that Plaintiff’s Wage Payment and Collection Law (WPCL) and Bad Faith claims were preempted by ERISA. Plaintiff alleged she was wrongfully denied disability benefits under her ERISA benefit plan, however her claims were a result of the denial of disability benefits, items which plainly “related to” her ERISA plan. 

Date of Decision:  February 3, 2006

McBride v. Hartford Life & Accident Ins. Co., United States District Court, E.D. PA, Civil Action No. 05-6172, 2006 U.S. Dist. LEXIS 4278 (E. D. Pa. Feb. 3, 2006) (Yohn, J.)