Rizzi v. Blue Cross of Southern California

Opinion

WORK, J.

Anthony Rizzi appeals a summary judgment for Blue Cross of Southern California (Blue Cross) after the trial court concluded Rizzi’s complaint—alleging, inter alia, violations of California Insurance Code section 790.03 in the denial of his claim for medical benefits under his employer’s group insurance policy—was preempted by the Employee Retirement Income Security Act (ERISA; see 29 U.S.C. 1 § 1001 et seq.). We affirm the judgment because we conclude substantial evidence supports the trial court’s finding the group insurance program was an employee welfare benefit plan…