Supreme Court Endorses Broad ERISA Preemption of Pure Eligibility Determinations by Plan Administrator; Federal Court the Exclusive Forum for Such Claims; Overlapping State Law Causes of Action Not Permitted (Recent Court Decisions) (Employee Retirement Income Security Act of 1974‪)‬

Aetna Health, Inc. v. Davila, 124 S. Ct. 2488, 159 L.Ed. 2d 312, 72 U.S.L.W. 4516, 2004 U.S. LEXIS 4571 (United States Supreme Court--March 23, 2004) Juan Davila was a participant in an employer-provided benefit plan subject to ERISA (the Employee Retirement Income Security Act of 1974) and Ruby Calad was a beneficiary under another such plan. Under the terms of Davila's plan, administered by Aetna Health, Inc. (formerly Aetna U.S. Healthcare), requests for coverage and payment to health-care providers are reviewed by Aetna. Cigna Healthcare of Texas provided similar administration of Calad's plan.