Rita Fromm v. Principal Health Care of Iowa, Inc., and Lou Garcia

Appellant Rita Fromm (“Fromm”) brought this action against Appellees Principal Health Care of Iowa, Inc. (“Principal”) and its executive director, Lou Garcia, challenging the denial of certain medical benefits she requested under an employee health insurance plan. Fromm’s sole claim was that the denial of benefits violated the Employee Retirement Income Security Act (“ERISA”), specifically 29 U.S.C. § 1132(a)(1)(B). Principal moved to dismiss the complaint under Federal Rule of Civil Procedure 12(b)(1) on the ground that Fromm’s health insurance coverage was the result of employment with the…