Ciampi v. Hannaford Bros. Co.

681 A.2d 4 (1996)

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Ciampi v. Hannaford Bros. Co.

Maine Supreme Judicial Court
681 A.2d 4 (1996)

Facts

Theresa Ciampi (plaintiff) was employed by Hannaford Bros. Co. (Hannaford) (defendant) when she suffered a work-related injury in January 1993. During the period of Ciampi’s disability, her fringe benefits were discontinued. Ciampi filed a petition seeking the inclusion of fringe benefits in her average weekly wage, at $63.50 weekly, which was the value of the benefits. The Workers’ Compensation Board (the board) granted her petition on the basis that the inclusion of benefits would not increase her weekly benefits above two-thirds of the state average weekly wage at the time of injury. Hannaford appealed, arguing that 39-A Maine Revised Statutes Annotated § 102(4)(H) was preempted by the Employee Retirement Income Security Act of 1974 (ERISA). The board did not address Hannaford’s argument, finding that it lacked jurisdiction to resolve federal preemption issues. Hannaford filed a petition for review with the Maine Supreme Judicial Court. Hannaford argued that § 102(4)(H) was superseded by ERISA because it had a connection with ERISA benefit plans, in that it increased the costs of providing ERISA benefits, created administrative burdens in existing plans, and subjected employers to conflicting laws.

Rule of Law

Issue

Holding and Reasoning (Roberts, J.)

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