Mealey's (August 11, 2020, 10:48 AM EDT) -- ST. LOUIS — The Eighth Circuit U.S. Court of Appeals on Aug. 7 reversed a lower court judgment by ruling that two sections of North Dakota's code that regulate the practices of pharmaceutical benefit managers (PBMs) make implicit reference to the Employee Retirement Income Security Act and, therefore, trigger preemption from the federal law (Pharmaceutical Management Care Association v. Marilyn Tufte, et al., No. 18-2926, 8th Cir., 2020 U.S. App. LEXIS 24922)....