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Case law update. State law negligence actions against MCOs are pre-empted by ERISA.

Facts: Juan Davila was a participant in an ERISA-regulated health plan administered by Aetna Health, Inc. His treating physician prescribed Vioxx to treat his arthritis pain, but Aetna refused to pay for it. Davila did not contest this decision, nor did he purchase Vioxx on his own and then seek reimbursement. Rather, he began taking Naprosyn for which, presumably, Aetna did pay. Davila experienced a severe reaction to the Naprosyn that required extensive treatment and hospitalization. Ruby Calad was a beneficiary of an ERISA-regulated health plan administered by CIGNA Healthcare of Texas, Inc. She underwent surgery. Her physician recommended an extended stay in the hospital, but CIGNA denied coverage for the extended stay. Following her discharge she suffered complications that required re-admission to the hospital. She claimed that her re-admission would not have occurred had her original stay been extended. Both Mr. Davila and Ms. Calad filed actions under the Texas Health Care Liability Act (THCLA), alleging that the actions of the health plans violated the plans' duties to “exercise reasonable care when making health care treatment decisions” as required by the THCLA. The actions were removed to federal district court, and were dismissed by the district courts. The U. S. Court of Appeals for the Fifth Circuit consolidated the claims on appeal and reversed the dismissal. This appeal to the Supreme Court ensued.