Ohio Department of Liquor Control v. Brookpark Entertainment, Inc.

How later courts describe this case

• recognizing that a claim "relates to a plan" when the very essence of the claim is premised on the existence of an employee benefit plan
• holding ERISA preempts any state law cause of action which relates to an employee benefit claim
• “Firestone ... [cannot] be read to reduce the standing question to a straightforward formula applicable in all cases.”
• claim based upon an employer's misrepresentations regarding the terms of a plan itself is preempted
• plaintiff must be in possession of two facts: “(1) an injury has occurred; and (2) the identity of the person who inflicted the injury” before limitations period accrues
• the focus of plaintiffs state law claims, the action of his employer in amending his ERISA plan and failing to disclose certain terms of the plan, related directly to the operation of an ERISA plan
• discussing § 1132, which provides for civil actions under ERISA
• claims for fraud, negligence, and gross negligence