Mealey's (May 6, 2021, 2:15 PM EDT) -- HOUSTON — Texas law clearly rejects the creation of an implied right of action in the state’s emergency care law, but a certified question to the Texas Supreme Court is unwarranted anyway because a federal appeals court can decide the case on the question of preemption under the Employee Retirement Income Security Act, an insurer argues in a May 3 response to a request that the Fifth Circuit U.S. Circuit Court of Appeals certify a question....