Gobeille v. Liberty Mutual Insurance Company

The state of Vermont (defendant) enacted a law requiring health insurers and healthcare providers to report any information relating to healthcare costs to a state agency. Insurers were also required to submit data on members’ claims. The federal Employee Retirement Income Security Act of 1974 (ERISA) included a clause preempting all state laws relating to employee benefit plans. Liberty Mutual Insurance Company (Liberty) (plaintiff) offered a health plan to its employees. Liberty’s plan was subject to ERISA regulations. Liberty’s plan was administered through Blue Cross Blue Shield (Blue Cross). Vermont issued a subpoena to Blue Cross, ordering Blue Cross to transmit all the files it possessed on members in Vermont. Liberty, concerned that such disclosure might violate its duty of confidentiality, instructed Blue Cross not to comply. Liberty then filed suit in federal court, seeking a declaration that ERISA preempted application of Vermont’s statute. Liberty also sought an injunction forbidding Vermont from trying to acquire data about Liberty’s health insurance plan. Vermont argued that Liberty could not properly bring a claim because Liberty did not demonstrate that it suffered economic damage. Vermont also argued that its law was proper because states traditionally had the power to regulate the area of public health. The trial court granted summary judgment to Vermont. The appeals court reversed. The case was then brought before the Supreme Court of the United States.