ERISA: Claim Denials – Preemption – Breach Of Contract

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(1)Where healthcare providers brought an action against an insurer and claims adjuster seeking damages and equitable relief for the alleged wrongful denial of claims, the insurer’s published claims procedures did not include language that could be interpreted as an offer, so the court properly found that the administrative guide was not a contract offer.

(2)Where healthcare providers brought claims against an insurer under the Missouri Prompt Payment Act, the district court properly concluded that the MPPA remedies were preempted by ERISA, and the court did not err in declining to impose a lengthy injunction detailing the handling of future claims because the plaintiffs have an adequate remedy under ERISA and state law.

Judgment is affirmed.

Schoedinger v. United Healthcare of the Midwest, Inc. (MLW No. 58771/Case No. 07-3317 – 11 pages) (U.S. Court of Appeals, Eighth Circuit, Loken, C.J.) Appealed from U.S. District Court, Eastern District of Missouri, Limbaugh, J. (Stefan J. Glynias, St. Louis, argued for appellant; Matthew S. McBride appeared on appellant’s brief) (Allen D. Allred, St. Louis, argued for appellee; Jeffrey R. Fink also appeared on appellee’s brief).