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Dukes v. U.S. Healthcare, Inc.

57 F.3d 350 (1995)

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Dukes v. U.S. Healthcare, Inc.

United States Court of Appeals for the Third Circuit
57 F.3d 350 (1995)

  • Written by Haley Gintis, JD

Facts

Cecilia Dukes and Ronald and Linda Visconti (plaintiffs) (collectively, the enrollees) filed separate actions in Pennsylvania state court against the health-maintenance organization (HMO) U.S. Healthcare, Inc. (the HMO) (defendant). The HMO administered a health plan governed by the Employee Retirement Income Security Act of 1974 (ERISA). The enrollees alleged that physicians associated with the HMO committed medical malpractice and that the HMO was liable for negligence regarding the malpractice on ostensible-agency and direct-negligence theories. The HMO removed the claims to federal court on the ground that the plans were governed by ERISA, which was a federal law that preempted any state-law tort claims. The enrollees moved to remand the claims back to state court. The HMO moved to dismiss on preemption grounds. The district court granted the HMO’s motion. The enrollees appealed. The United States Court of Appeals for the Third Circuit consolidated the appeals to consider whether removal of a claim regarding the quality of a healthcare benefit was appropriate.

Rule of Law

Issue

Holding and Reasoning (Stapleton, J.)

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