Mealey's (November 20, 2020, 1:15 PM EST) -- WASHINGTON, D.C. — The U.S. Supreme Court should review the Eighth Circuit U.S. Court of Appeals’ ruling that the Employee Retirement Income Security Act preempts two sections of North Dakota’s code that regulate the practices of pharmaceutical benefit managers (PBMs) because ERISA preempts only state laws that apply to ERISA plans and not to non-ERISA plans, North Dakota officials contend in a Nov. 13 petition for writ of certiorari (Dirk Wilke, et al., v. Pharmaceutical Care Management Association, No. 20-683, U.S. Sup.)....