NOVEMBER 2006 BAD FAITH CASES
BAD FAITH CLAIM PREEMPTED BY ERISA (Philadelphia Federal)
In Maldonado v. Unum Life Insurance Company of America, Plaintiff filed suit to recover disability benefits under a group disability plan, administered by Defendant on behalf of Plaintiff’s employer. Plaintiff alleged various state law claims, including bad faith. The United States District Court for the Eastern District of Pennsylvania looked to ERISA’s express preemption provision, which provides that ERISA “shall supersede any and all state laws insofar as they may now or hereafter relate to any employee benefit plan.” The Court recognized that state law claims that are subjected to express preemption are displaced and thus subject to dismissal. The Court found that Plaintiff’s bad faith claim under Pennsylvania’s bad faith statute related to an employee benefit plan and was expressly preempted by ERISA. Thus the Court granted Defendant’s Motion to Dismiss Plaintiff’s bad faith complaint.
Date of Decision: October 31, 2006