Metropolitan Life Ins. Co. v. Taylor
481 U.S. 58 (1987)
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Rule of Law:
State common law claims falling within the scope of the civil enforcement provisions of the Employee Retirement Income Security Act (ERISA), § 502(a), are not only pre-empted but are also displaced by ERISA's federal cause of action, converting them into federal claims that are removable to federal court under the 'complete pre-emption' doctrine.
Facts:
- General Motors Corporation (General Motors) maintained an employee benefit plan for its salaried employees, which was subject to ERISA and insured by Metropolitan Life Insurance Company (Metropolitan).
- Arthur Taylor, a salaried employee at General Motors, took a leave of absence in May 1980 due to severe emotional problems.
- Metropolitan initially paid Taylor disability benefits under the plan but terminated them in July 1980 after its designated psychiatrist determined Taylor was fit to return to work.
- Taylor then filed a supplemental claim for disability based on a pre-existing back injury, which Metropolitan also denied after an orthopedic examination revealed no disabling condition.
- A General Motors physician also examined Taylor and concluded he was not disabled.
- When Taylor refused to return to his job, General Motors terminated his employment.
Procedural Posture:
- Arthur Taylor sued General Motors and Metropolitan in Michigan state court, asserting various state common law claims related to his disability benefits and termination.
- General Motors and Metropolitan removed the case to the U.S. District Court for the Eastern District of Michigan, alleging federal question jurisdiction under ERISA.
- The District Court found the case was properly removed and granted summary judgment in favor of General Motors and Metropolitan.
- Taylor, as appellant, appealed to the U.S. Court of Appeals for the Sixth Circuit.
- The Court of Appeals reversed the District Court's decision, holding that the court lacked removal jurisdiction because Taylor’s complaint only raised state law claims and did not fall under the 'well-pleaded complaint' rule.
- General Motors and Metropolitan, as petitioners, were granted a writ of certiorari by the U.S. Supreme Court.
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Issue:
Does the Employee Retirement Income Security Act (ERISA) so completely pre-empt state common law claims for benefits under an ERISA-regulated plan that such claims are necessarily federal in character and thus removable to federal court, creating an exception to the well-pleaded complaint rule?
Opinions:
Majority - Justice O'Connor
Yes. The civil enforcement provisions of ERISA completely pre-empt state law claims for benefits, converting them into federal causes of action that are removable to federal court. The general rule of federal question jurisdiction, the 'well-pleaded complaint' rule, typically prevents removal based on a federal defense. However, an exception exists where Congress so completely pre-empts a field that any claim is necessarily federal in character, a principle established for the Labor Management Relations Act (LMRA) in Avco Corp. v. Machinists. The Court finds that Congress clearly intended for ERISA's civil enforcement provision, § 502(a), to have the same powerful, displacing effect as § 301 of the LMRA. This intent is evident from the parallel language in the statutes' jurisdictional grants and, more explicitly, from ERISA's legislative history, which states that such actions 'are to be regarded as arising under the laws of the United States in similar fashion to those brought under section 301 of the Labor-Management Relations Act.' Therefore, Taylor's suit, though styled as a state-law action, falls within the scope of § 502(a) and is properly removable to federal court.
Concurring - Justice Brennan
Yes. The court correctly holds that Congress's clear intent makes these causes of action removable. This holding, however, should be interpreted narrowly. This decision does not create a broad rule that any federal pre-emption defense is sufficient to justify removal from state to federal court. Removal jurisdiction exists here only because Congress clearly manifested an intent to make causes of action within the scope of ERISA § 502(a) removable. In future cases involving other statutes, federal courts should remand cases to state court unless they find a similarly clear congressional intent to create removal jurisdiction.
Analysis:
This case establishes the doctrine of 'complete pre-emption' for ERISA § 502(a) claims, creating a significant corollary to the well-pleaded complaint rule. By extending the jurisdictional analysis from LMRA § 301 to ERISA, the Court dramatically shifted employee benefits litigation from state to federal courts. This decision ensures uniform federal regulation of benefit plans and prevents plaintiffs from using state tort law to obtain remedies that Congress did not provide in ERISA. As a practical matter, it empowers defendants in benefits disputes to remove cases to federal court, which is often seen as a more favorable forum with more limited remedies.
