Quimbee logo
DMCA.com Protection Status
From our private database of 19,800+ case briefs...

American Medical Security, Inc. v. Bartlett

United States Court of Appeals for the Fourth Circuit
111 F.3d 358 (1997)


Instead of buying health insurance, some Maryland employers funded their own employee health plans. To limit financial risks, the employers purchased stop-loss insurance policies to cover any medical expenses for a given employee above a specified point, which was known as the attachment point. Under this system, the employer paid an employee’s healthcare costs up to the attachment point. If the employee had medical expenses exceeding that amount, the employer made a claim under the stop-loss policy to cover the extra expenses. A self-funded employer health plan was not considered insurance and was not regulated by state insurance laws. Maryland required that health-insurance policies provide 28 specific types of coverage. Maryland’s insurance commissioner, Dwight Bartlett (defendant), was concerned that employers would dodge this regulation by creating what would technically be self-funded health plans but with very low attachment points. In that scenario, most of an employer’s risk would still be insured but not subject to the state’s insurance laws. Thus, employees under those plans might not get many of the 28 types of mandatory health coverage. To try to close this loophole, the commissioner enacted regulations stating that any stop-loss insurance policy with an attachment point of less than $10,000 per employee was actually a health-insurance policy and subject to the mandatory-coverage law. Employers with self-funded health plans (the employers) (plaintiffs) sued, claiming that the attachment-point rule was preempted by the federal Employee Retirement Income Security Act (ERISA). The district court entered summary judgment in favor of the employers. The case ended up before the Fourth Circuit.

Rule of Law


Holding and Reasoning (Niemeyer, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 510,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.

Here's why 510,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 19,800 briefs, keyed to 985 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Questions & Answers

Have a question about this case?

Sign up for a free 7-day trial and ask it

Sign up for a FREE 7-day trial