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Kentucky Association of Health Plans, Inc. v. Miller
United States Supreme Court
538 U.S. 329 (2003)
Kentucky statutes prohibited any health insurer from discriminating against healthcare providers and chiropractors who were willing and able to meet the terms and conditions for participation in the insurer’s health-insurance plan. These statutes were known as Any Willing Provider (AWP) statutes. The Kentucky Association of Health Plans, Inc., and several HMOs (plaintiffs) challenged the AWP statutes on the ground that the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. § 1140, preempted state laws relating to plans governed by ERISA. The district court found that the AWP statutes were related to ERISA plans but fell within an exception to the preemption provision, because the statutes regulated insurance. The United States Court of Appeals for the Sixth Circuit affirmed. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Scalia, J.)
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