Mealey's (April 7, 2016, 9:43 AM EDT) -- SAN FRANCISCO — Because a claim for intentional infliction of emotional distress is only “tangentially related” to the administration of a disability plan, a claim for intentional infliction of emotional distress alleged against a disability insurer is not preempted by the Employee Retirement Income Security Act, a California federal judge said April 4 (John Kresich v. Metropolitan Life Insurance Co.,, No. 15-5801, N.D. Calif.; 2016 U.S. Dist. LEXIS 45503)....