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Pilot Life Insurance Company v. Dedeaux
United States Supreme Court
481 U.S. 41 (1987)
Everate Dedeaux (plaintiff) was an employee of Entex, Inc. (Entex). Entex had a long-term disability employee-benefit plan through Pilot Life Insurance Company (Pilot) (defendant). Entex provided its employees with the forms for processing claims and forwarded these completed forms to Pilot. Pilot determined who qualified for benefits under the plan. Dedeaux was injured in connection with his employment with Entex. Dedeaux sought disability benefits. Pilot paid benefits to Dedeaux for two years but then terminated those benefits. Over the next three years, Pilot reinstated and terminated Dedeaux’s benefits several times. Dedeaux sued Pilot, alleging common-law claims and bad faith. Dedeaux did not assert any claims under the Employee Retirement Income Security Act of 1975 (ERISA). Pilot moved for summary judgment, arguing that ERISA preempted Dedeaux’s common-law claims. The district court granted summary judgment to Pilot, holding that Dedeaux’s claims were preempted by ERISA. The United States Court of Appeals for the Fifth Circuit reversed. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (O’Connor, J.)
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