(March 31, 2017, 3:39 PM EDT) -- RIVERSIDE, Calif. — Because a short-term disability plan is a self-funded plan, the Employee Retirement Income Security Act preempts a California statute that bars the plan’s discretionary authority provision, a California federal judge said March 28 in determining that the plan’s denial of benefits was supported by substantial evidence (Daniel Johnson v. Aetna Life Insurance Co., et al., No. 15-1940, C.D. Calif., 2017 U.S. Dist. LEXIS 45858)....