Benefit Strategies West, Inc., et al. v. Roger Naumann, et al.
Arbitration ERISA Privacy
Whether the Arizona Court of Appeals violated ERISA's exclusive federal jurisdiction and preemption doctrine by asserting state law and state-court jurisdiction over an ERISA dispute
QUESTION PRESENTED The Ninth Circuit, stepping out from the other circuits, rendered federal jurisdictional decisions in Paulsen v. CNF, Inc. and Batford v. Northrup Grum— man Corp. that appear to vitiate ERISA’s exclusive jurisdiction and supersedure statutes and preemption doctrine in a way that would allow state courts to use state law to render uninformed, incorrect and conflicting rulings about federal matters, and in the case at bar a state court relied on those cases in asserting state court jurisdiction and applying state law to an ERISA dispute. In that context, the question presented is whether the Arizona Court of Appeals, relying on Paulsen and especially on Safford, violated ERISA’s exclusive federal jurisdiction and supersedure statutes and preemption doctrine by asserting state law and statecourt jurisdiction over a case an ERISA plan’s trustees and participant brought against the plan’s drafter and administrator about whether the plan was drafted and administered in accordance with federal ERISA law.