Subassignees’s Claims Were Preempted By ERISA, 11th Circuit Says

(December 7, 2015, 10:41 AM EST) -- ATLANTA — The 11th Circuit U.S. Court of Appeals on Dec. 1 declined to rule that the Employee Retirement Income Security Act prohibits non-health-care providers from obtaining derivative standing through a subassignment in affirming a district court’s holding that state law claims by a participant’s subassignee are completely preempted by ERISA (Gables Insurance Recovery Inc., as assignee of South Miami Chiropractic LLC, v. Blue Cross and Blue Shield of Florida Inc., No. 15-10459, 11th Cir.; 2015 U.S. App. LEXIS 20789)....

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