Betancourt v. Storke Housing Investors

Opinion

CHIN, J.

We granted review to determine whether the federal Employee Retirement Income Security Act of 1974 (ERISA) (29 U.S.C. § 1001 et seq.) preempts a mechanic’s lien action (Civ. Code, § 3110) 1 brought by laborers to recover unpaid contributions to their employee benefit plans. ERISA preempts state laws that “relate to” employee benefit plans. (29 U.S.C. § 1144(a).) In 1991, we held that ERISA preempted a similar mechanic’s lien statute (§ 3111) that “single[d] out ERISA plans for special treatment” and, thus, related to employee benefit plans. (Carpenters So. Cal. Admin. Corp. v.…