O'Neil v. Wal-Mart
United States District Court for the Northern District of New York
502 Fed. Supp. 2d 318 (2007)
- Written by Mary Katherine Cunningham, JD
Facts
The Commissioner of Essex County Department of Social Services (the commissioner) (plaintiff) filed a suit against Wal-Mart Stores, Inc. Associates’ Health and Welfare Plan (the Plan) (defendant). The Plan denied health-insurance benefits to WPL, the stepson of Wal-Mart employee Amie Vradenburg pursuant to a qualified medical child support order (QMCSO). The commissioner asserted that the QMCSO was legitimate and that the Plan was required under 29 U.S.C. § 1169(a)(4) and New York Insurance Law Section 2608–a. The Plan asserted that the QMCSO was not a valid QMCSO under Section 1169 of Title 29 of the United States Code and that the Employee Retirement Income Security Act of 1974 (ERISA) preempted the New York Insurance Law. The Plan alternatively argued that WPL did not meet the eligibility guidelines for certain health-insurance benefits as Vradenburg’s stepson and the QMCSO could not override the eligibility guidelines. The Plan and the commissioner filed competing motions for summary judgement, as no issue of material fact existed.
Rule of Law
Issue
Holding and Reasoning (Kahn, J.)
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