Self-Insurance Institute of America v. Snyder, Governor of Michigan, et al.

Supreme Court Reviews Sixth Circuit's ERISA Interpretation

Term: 2015 Term
Oral Argument Date:
Vote: GVR
Opinion: Per Curiam
Questions Presented: 

Whether a state law that imposes new reporting, payment, recordkeeping, and audit requirements on ERISA plan administrators that arise directly from their processing of welfare benefit claims pursuant to ERISA “relate[s] to” ERISA benefit plans and is therefore preempted under 29 U.S.C. § 1144(a); and   

Whether the broad preemption language in 29 U.S.C. § 1144(a) can be judicially narrowed to accommodate a presumption against preemption of newly minted state laws that seek to exploit the core functions of ERISA plan administrators.

U.S. Chamber's Position: 

In its brief, the U.S. Chamber argues that the Sixth Circuit’s decision threatens to undermine the uniformity intended by Congress, as reflected in ERISA’s broad preemption provision, by opening the door to the proliferation of state laws that burden and complicate the administration of employer health plans. If allowed to stand, the decision of the Sixth Circuit could portend trouble for the viability of employer-provided health care benefits.

This case presents an exceptionally important issue about the interpretation of ERISA’s broad preemption provision; its role in minimizing burdensome, costly, and potentially conflicting state regulatory requirements on ERISA plans; and its importance in eliminating impediments to employers who want to continue offering health care plans to their employees.

Carol Connor Cohen and Caroline Turner English of Arent Fox LLP represented the U.S. Chamber of Commerce as co-counsel to the U.S. Chamber Litigation Center in this case. 

Outcome Content: 

The Supreme Court vacated the judgment and remanded the case to the Sixth Circuit for further consideration in light of Gobeille v. Liberty Mutual Insurance Company.

Procedural History: 

Cert. petition filed 12/18/2014.  U.S. Chamber amicus brief filed 1/22/2015. Decided 3/7/2016.