Self-Insurance Institute of America, Inc. v. Snyder

OPINION

KAREN NELSON MOORE, Circuit Judge.

This case requires us, once again, to navigate the quagmire that is preemption. Plaintiff-Appellant, which represents various sponsors and administrators of self-funded ERISA benefit plans, argues that federal law — the Supremacy Clause, U.S. Const, art. VI, § 2, and ERISA’s express-preemption provision, 29 U.S.C. § 1144(a) — prohibits the application of a Michigan statute to ERISA-covered entities. The Michigan statute, however, escapes the preemptive reach of federal law, and we AFFIRM the district court’s dismissal of the suit.

I. BACKGROUND

In 2011,…