State Law Tort Claims Preempted by ERISA

Cacoperdo v. Hartford Life Ins. Co. (S.D.N.Y., Oct. 5, 2011)

The plaintiff, as policyholder, brought suit against two medical evaluation service providers for tortious interference. The policyholder claimed that the two providers knew or should have known that a valid contract existed between the policyholder and the insurer and that they induced the insurer to breach the contract by creating medical findings and opinions that led to the insurer’s failure to discharge its duties and obligations with respect to the policyholder’s LTD benefits. The court stated that a benefits determination under ERISA supersedes any and all state laws insofar as they relate to any employee benefit plan. The court found that the policyholder would not have a state law claim to bring if the insurer did not deny his LTD benefits, because neither of the providers owed the plaintiff an independent legal duty. Therefore, the plaintiff’s state law claims are preempted as they directly relate to the insurer’s administration of the plan benefits.