(November 17, 2017, 11:19 AM EST) -- SAN DIEGO — Because a negligence claim against a health insurer is seeking damages related to the release of private medical information rather than a denial of benefits, the negligence claim is not preempted by the Employee Retirement Income Security Act, a California federal judge said Nov. 9 in denying the insurer’s motion to dismiss (James Heldt v. The Guardian Life Insurance Company of America, No. 16-885, S.D. Calif., 2017 U.S. Dist. LEXIS 186299)....