UnitedHealth Axes Reimbursement Suit on ERISA Preemption Grounds

December 2, 2025, 11:06 PM UTC

UnitedHealth Group Inc. defeated an insurance reimbursement suit Tuesday after a federal appeals court affirmed the Employee Retirement Income Security Act’s broad preemptive power over state claims brought by a plan participant.

Since Eric Patterson’s Ohio state law claims against his insurer and health plan administrator UnitedHealth were claims to recover ERISA plan benefits, they are subject to complete preemption, Judge Chad A. Readler of the US Court of Appeals for the Sixth Circuit said affirming dismissal Tuesday.

Patterson was injured in a car accident, received medical care covered by his UnitedHealth insurance plan, and then recovered damages from the ...

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