Whether the anti-assignment provision in the health benefit plan apply to W. A. Griffin, MD

QUESTIONS PRESENTED : Whether the anti-assignment provision in the , health benefit plan apply to W. A. Griffin, MD (“Dr. Griffin”), a Georgia provider, who obtained ; a written assignment of benefit from her patient — in accordance with Georgia State mandatory assignment of benefit law (Georgia § 33-24-54). : Anti-assignment and anti-alienation provisions , contained in employer sponsored group health benefit plans subject to the Employee Retirement | Investment: Security Act of 1974 (“ERISA”) are usually not applicable to an assignee who is the provider of the services which the plans are maintained to furnish. Dr. Griffin provided health services to Patient J.A., an individual — covered by the Motion Picture Industry Health ‘ Plan, employer-sponsored group health benefit plan (“Motion Picture Plan”), and Patient J. A. executed a written assignment benefit to Dr. Griffin that states this assignment is a “direct legal assignment of [Patient J.A.’s] rights and benefits under” the Plan. The District Court and the Eleventh Circuit have repeatedly . stated that the language “rights and benefits” ; does not cover rights to statutory penalties and/or breaches of fiduciary duty claims and that Dr. Griffin does not have a _ valid ; , assignment of benefit, because the state assignment law is pre-empted by ERISA. . ii . QUESTIONS PRESENTED Even though Dr. Griffin has shown the District Court this Court’s instructive authority that clearly illustrates that the Georgia assignment of benefit statue is not pre-empted by ERISA in Rutledge, it refuses to acknowledge that Dr. Griffin has a valid assignment (or any rights ) that ; pertain to an assignment of benefit obtained in accordance with Georgia law. Rutledge v. Pharm. Care Mgmt. Ass’n, No. 18-540, 2020 WL 7250098 ‘S. Ct. 10 Dec. 2020) The question is whether a writ of mandamus should be issued directing the District Court to halt the unlawful blockade of Dr. Griffin’s payment and : non-payment related ERISA rights. Rutledge clearly directs every court to enforce the U.S. Supreme Court's order.