Mealey's (May 25, 2021, 12:31 PM EDT) -- SAN DIEGO — A disability claimant’s intentional infliction of emotional distress claim arising out of a third-party claims administrator’s treatment of the claimant is not preempted by the Employee Retirement Income Security Act because the claim does not relate to or depend on the claimant’s ERISA benefits plan, a California federal judge said May 24 in denying a disability insurer’s motion to dismiss....