No. 21-1516

Swagelok Associates Welfare Benefits Plan v. Laura Patterson, et vir

Lower Court: Ohio
Docketed: 2022-06-02
Status: Denied
Type: Paid
Tags: civil-procedure equitable-relief erisa exclusive-jurisdiction federal-jurisdiction plan-participant reimbursement state-court-jurisdiction welfare-benefits
Key Terms:
Arbitration ERISA HabeasCorpus Privacy Jurisdiction
Latest Conference: 2022-09-28
Question Presented (AI Summary)

Is a state law action brought by a Plan Participant for an injunction barring an ERISA welfare benefit plan from enforcing its terms a claim for equitable relief pursuant to ERISA Section 502(a)(3), 29 U.S.C. 1132(a)(3), and therefore a claim over which the federal courts have exclusive jurisdiction under Section 502(e)(1), 29 U.S.C. 1132(e)(1), or may such an action proceed in state court?

Question Presented (from Petition)

QUESTION PRESENTED Petitioner Swagelok Associates Welfare Benefits Plan (the “Plan”) provided medical benefits coverage to Respondent Laura Patterson when she was injured in an automobile accident. Ms. Patterson filed an action in the Ohio Court of Common Pleas, seeking a declaration that the Plan had no right to reimbursement out of Ms. Patterson’s potential third party recovery, and to “bar” the Plan from enforcing its reimbursement rights with respect to any potential recovery she received from a third party in connection with the accident. The Ohio Court of Appeals for the Ninth District, Summit County, construed the Pattersons’ claims as arising under both ERISA Section 502(a)(1)(B) and Section 502(a)(3), and held that, because the claim was, in part, a claim for benefits under Section 502(a)(1)(B), the state court had jurisdiction over the matter pursuant to ERISA Section 502(e)(1). The Ohio Supreme Court rejected the Plan’s request to take jurisdiction of an appeal, thereby affirming the Ohio Appellate Court’s ruling. The question presented is: Is a state law action brought by a Plan Participant for an injunction barring an ERISA welfare benefit plan from enforcing its terms a claim for equitable relief pursuant to ERISA Section 502(a)(3), 29 U.S.C. 1132(a)(3), and therefore a claim over which the federal courts have exclusive jurisdiction under Section 502(e)(1), 29 U.S.C. 1132(e)(1), or may such an action proceed in state court?

Docket Entries

2022-10-03
Petition DENIED.
2022-08-17
DISTRIBUTED for Conference of 9/28/2022.
2022-08-16
Reply of petitioner Swagelok Associates Welfare Benefits Plan filed. (Distributed)
2022-08-02
Brief of respondents Laura Patterson, et vir in opposition filed.
2022-06-29
Motion to extend the time to file a response is granted and the time is extended to and including August 4, 2022.
2022-06-27
Motion to extend the time to file a response from July 5, 2022 to August 4, 2022, submitted to The Clerk.
2022-05-31
Petition for a writ of certiorari filed. (Response due July 5, 2022)
2022-04-20
Application (21A628) granted by Justice Kavanaugh extending the time to file until May 31, 2022.
2022-04-18
Application (21A628) to extend the time to file a petition for a writ of certiorari from May 2, 2022 to May 31, 2022, submitted to Justice Kavanaugh.

Attorneys

Laura Patterson, et vir
Benjamin Paul PfoutsKisling, Nestico & Redick, LLC, Respondent
Benjamin Paul PfoutsKisling, Nestico & Redick, LLC, Respondent
Swagelok Associates Welfare Benefits Plan
Noah Gordon LipschultzLittler Mendelson, PC, Petitioner
Noah Gordon LipschultzLittler Mendelson, PC, Petitioner