Gobeille v. Liberty Mutual Insurance Company

Supreme Court Holds that State All-Payer Claims Database Laws are Preempted by ERISA

Term: 2015 Term
Oral Argument Date: Dec 2, 2015
Vote: 6-2
Opinion: Kennedy
Questions Presented: 

Did the Second Circuit – in a 2-1 panel decision that disregarded the considered opinion advanced by the United States as amicus – err in holding that ERISA preempts Vermont’s health care database law as applied to the third-party administrator for a self-funded ERISA plan?

U.S. Chamber's Position: 

In a coalition amicus brief, the U.S. Chamber argued that the Supreme Court should affirm the Second Circuit’s decision that ERISA preempts Vermont’s health care database law as applied to the third-party administrator of a self-funded ERISA plan.

In its brief, the Chamber explains the operation of self-funded ERISA plans, describes the benefits of these plans to employers and employees, and examines how claims database laws like Vermont’s impose a substantial burden on self-funded employer plans due to conflicting state requirements. In addition, the brief argues that ERISA benefit plans have the exclusive purpose of providing benefits, and may not be drafted to fulfill a state’s interest in data collection. 

The brief was filed jointly with the American Benefits Council, America's Health Insurance Plans, ERISA Industry Committee, HR Policy Association, and National Business Group on Health.

Brian D. Netter, Matthew A. Waring, and Nancy G. Ross of Mayer Brown LLP served as co-counsel for the amici with the U.S. Chamber Litigation Center.

Outcome Content: 

By a 6-2 vote, the Supreme Court held ERISA pre-empts Vermont’s statute as applied to ERISA plans.  As the Court explained, “The state statute imposes duties that are inconsistent with the central design of ERISA, which is to provide a single uniform national scheme for the administration of ERISA plans without interference from laws of the several States even when those laws, to a large extent, impose parallel requirements."

Justices in Minority: 
Procedural History: 

Cert. petition granted 6/29/2015. U.S. Chamber amicus brief filed 10/20/2015.

Argued 12/2/2015. Decided 3/1/2016.