Corcoran v. United Healthcare

Florence Corcoran (plaintiff) was a longtime employee of South Central Bell Telephone Company (Bell) and a member of its medical-assistance plan (the plan). A portion of the plan, known as the Quality Care Program (program), required participants to obtain precertification for overnight hospital admissions. The program was administered by United Healthcare, Inc. (UHC) (defendant) pursuant to an agreement with Bell. The program’s summary plan description included representations about UHC’s medical expertise, noting that, as part of the precertification process, UHC would assess the need for hospitalization and determine the appropriate length of stay. However, the summary plan description also stated that all decisions regarding a participant’s medical care were up to the participant and her physician. Corcoran was pregnant and with a previous pregnancy had undergone a successful preterm Cesarean section due to fetal distress. Corcoran’s obstetrician, Dr. Jason Collins, advised that this pregnancy was also high risk and ordered Corcoran hospitalized for the last month of the pregnancy so that the fetus could be monitored around the clock. Collins sought precertification for Corcoran’s hospitalization in accordance with the program. However, UHC determined that hospitalization was unnecessary and instead authorized 10 hours per day of home nursing care. While no nurse was on duty, Corcoran’s fetus went into distress and died. Corcoran and her husband filed a wrongful-death action in Louisiana state court, alleging, among other things, that UHC’s negligence caused the death of their unborn child. The Corcorans also sought emotional-distress damages. UHC removed the action to federal court. The district court ruled that Corcoran’s claims were preempted by the Employee Retirement Income Security Act (ERISA) and entered summary judgment in favor of UHC. Corcoran appealed.