Provience v. Valley Clerks Trust Fund

Opinion

SIMS, J.

In this case, we hold that tort claims for fraud, bad faith denial of benefits, and intentional infliction of emotional distress, asserted by an employee against an employee benefit plan subject to ERISA, 1 are preempted by ERISA and may not be litigated in the state courts of California.

Factual and Procedural Background

In June 1978 plaintiff obtained employment with Raley’s Markets. Raley’s offered plaintiff participation in one of two medical payment plans as a benefit of his employment. Plaintiff chose Valley Clerks Trust Fund (Fund), an employee benefit plan subject to…