Mealey's (August 10, 2015, 11:26 AM EDT) -- BOSTON — A federal district court properly refrained from ruling on whether ERISA preempted a state administrative agency’s investigation into whether a disability plan violated state law and the Americans with Disabilities Act by paying disparate benefits depending on whether an employee suffered from a physical or mental impairment, the First Circuit U.S. Court of Appeals ruled July 20 (Sirva Relocation, LLC, et al. v. Charlotte Golar Richie, No. 14-1934, 1st Cir.; 2015 U.S. App. LEXIS 12488)....