ERISA Industry Committee applauds appeals court ruling in Bristol v. Cigna

Washington, D.C., June 12, 2024 – The ERISA Industry Committee applauded the Ninth Circuit Court of Appeals’ decision in Bristol SL Holdings, Inc. v. Cigna Health & Life Ins. Co., which affirmed the previous ruling by the U.S. District Court for the Central District of California, which determined that the state law breach of contract and promissory estoppel claims at issue are preempted by the federal Employee Retirement Income Security Act.

In 2023, ERIC, in a collaborative effort with the American Benefits Council and the California Association of Health Plans, filed an amicus brief urging the Court to affirm the previous ruling by the U.S. District Court for the Central District of California. This joint filing was a focused effort to protect national uniformity on central plan design decisions and to highlight the substantial, real-world impacts of ERISA preemption on related lawsuits.

“We are pleased that the Ninth Circuit Court of Appeals solidified the concepts of ERISA preemption and recognized the arguments we put forward,” said Tom Christina, ERIC Legal Center Executive Director. “This case illustrated the substantial real-world impact that this kind of litigation has on plan administrators and demonstrates how such claims fundamentally interfere with the pre-authorization system meant to prevent unnecessary and excessive out-of-network expenditures.”

The case involved a now bankrupt out-of-network mental healthcare treatment center (Sure Haven, Inc.) that violated the plan's terms (fee-forgiving) but demanded plan payment. The provider's successor (Bristol SL Holdings, Inc.) sued, arguing there was a promise to pay for medical treatment even before treatment was provided. The Ninth Circuit Court of Appeals determined that the state-law claims were preempted by federal ERISA law because they have both a “reference to” and an “impermissible connection with” the ERISA plans administered by Cigna.

The brief is available here.