Koval v. Washington County Redevelopment Authority

OPINION OF THE COURT

FUENTES, Circuit Judge:

Appellant Joseph Koval contends that his former employer, the Washington County Redevelopment Authority (“WCRA”), arbitrarily revoked his retirement health plan in violation of Employee Retirement Income Security Act (“ERISA”), 29 U.S.C. §§ 1001-1461. The District Court dismissed Koval’s suit for lack of subject matter jurisdiction, finding that the WCRA plan was subject to ERISA’s exemption for “governmental plans.” 29 U.S.C. § 1003(b)(1). For the reasons set out below, we affirm the judgment of the District Court.

I

Joseph Koval is a former employee…