Powell v. Chesapeake & Potomac Telephone Co.

How later courts describe this case

• holding that claims of intentional infliction of emotional distress, breach of implied covenant of good faith, breach of contract, and violation of state’s Unfair Trade Practices Act were pre-empted by ERISA
• concluding, in a case decided before Pilot but consistent with it, that an action alleging improper claims processing is not saved from preemption because it does not regulate the business of insurance under ERISA
• concluding, in a case decided before Pilot Life but consistent with it, that an action alleging improper claims processing is not saved from preemption because it does not regulate the business of insurance under ERISA
• rejecting plaintiff's argument that beneficiaries may seek extra-contractual damages from a fiduciary as "other appropriate equitable relief" under traditional principles of trust law which Congress intended to engraft upon ERISA
• acknowledging prior approval of five yearperiod based on Mo.Rev.Stat. § 516.120
• “Since Connecticut General [Life Insurance Company] is not an ‘employee benefit plan,’ the deemer clause is inapplicable to it.”
• § 502(a)(3)’s provision for “other appropriate equitable relief” does not authorize extracontractual or punitive damages for the plan administrator’s breach of fiduciary duties under ERISA
• § 1132(a)(3) does not authorize extra-contractual or punitive damages for breach of a plan administrator's fiduciary duties under ERISA