Coleman v. Blue Cross & Blue Shield of Alabama, Inc.

Appellant challenges the dismissal of her declaratory judgment action. We find merit in two of appellant’s challenges. Namely, the trial court (1) incorrectly determined the exclusive jurisdiction over the cause of action was in federal court, and (2) prematurely dismissed the complaint based on the preemption provisions of the Employment Retirement Income Security Act (ERISA).1 We reverse and remand for further proceedings.

After successfully settling a personal injury action in federal court, appellant filed a complaint in state court requesting a declaratory judgment prohibiting appellee…