Cromwell v. Equicor-Equitable HCA Corp.

How later courts describe this case

• stating that such payments would “affect the relationship between plan principals by extending coverage beyond the terms of the plan”
• colleeting cases wherein state claims for breach of contract, promissory estoppel, negligence and misrepresentation of benefits were preempted by ERISA
• collecting cases wherein state claims for breach of contract, promissory estoppel, negligence and misrepresentation of benefits were preempted by ERISA
• finding preemption where health care provider sued plan administrator seeking recovery of plan benefits
• “We are aware that preemption normally is not dependent on the availability of ERISA remedies.”
• “A health care provider may assert an ERISA claim as a ‘beneficiary’ of an employee benefit plan if it has received a valid assignment of benefits.”