Federal Court Holds that Tennessee State Court Should Have Retained Jurisdiction Over Auto Accident Victim’s Claim Against Medical Provider

When someone is hurt in a Knoxville car accident, he or she is likely to have considerable medical costs. Getting those expenses paid can be an uphill battle, as can recouping lost wages or compensation for pain and suffering. In addition to a negligence lawsuit filed against the at-fault driver, the plaintiff may have other legal remedies available to him or her.

As the case set forth below explains, it is usually the plaintiff who decides where to file his or her lawsuit, if a choice of forum is a possibility (which it may or may not be, depending upon the circumstances), but there are sometimes exceptions to this general rule. As the court points out, there may also be an exception to the exception.

Facts of the Case

In a recent federal appellate case, the original plaintiff was a woman who was reportedly hurt in a car accident. She sought medical treatment from the defendant healthcare provider, who later billed her some $8000 for her treatment. Three different insurance companies paid monies to the defendant towards the cost of the plaintiff’s care: her employer-sponsored medical plan, her husband’s medical plan, and her automobile insurance plan. According to the plaintiff’s complaint, which she filed in Tennessee state court, the defendant overcharged her for her care and commonly did the same to others. The plaintiff’s suit sought to assert the rights of a putative class of individuals who had been subjected to the defendant’s practices.

During discovery, the defendant learned that the plaintiff’s husband’s plan, which had paid $100 towards her $8000 bill, was an ERISA plan. Based on this information, the defendant removed the case from state court to federal court based on the doctrine of “complete preemption” under ERISA. The United States District Court for the Western District of Tennessee at Memphis agreed with the defendant that this was proper, denied the plaintiff’s motion to remand, and, ultimately, entered a judgment in favor of the defendant. The plaintiff appealed.

The Appellate Court’s Decision

The United States Court of Appeals for the Sixth Circuit reversed. The court began its opinion with a perplexing statement: “The only rule without an exception is that every rule has an exception.” According to the court, the general rule is that the plaintiff in a civil action gets to choose the court in which to begin his or her legal action. However, there is an exception to the usual rule: complete preemption under ERISA. It was due to this purported rule (the exception to the general rule) that the federal district court held that the defendant’s removal of the plaintiff’s action was proper.

The appellate court pointed out that there are two forms of ERISA preemption: the more broadly applied express preemption and the more narrowly applied complete preemption. Under the circumstances presented in the case at bar, the plaintiff’s case was only removable by the defendant because the complete preemption doctrine was implicated. According to the court, ERISA did not completely preempt the plaintiff’s claim because she had not alleged a denial of benefits under her husband’s ERISA plan. The gravamen of the plaintiff’s suit was that the hospital had overcharged her for the treatment of her automobile accident related injuries; this was, in the court’s words, “far afield from the ‘heart’ of what ERISA governs: the rights of beneficiaries… against plan administrators.” (In other words, the court ruled that there was an exception to the rule of completed preemption under ERISA, which the defendant had argued was an exception to the usual rule that the plaintiff chooses his or her forum.)

Talk to an East Tennessee Accident Lawyer

If you have questions about seeking payment for medical expenses, lost wages, or pain and suffering due to a motor vehicle collision, experienced car accident attorney Mark Hartsoe at the Hartsoe Law Firm can help. For a free consultation, call us now at 865-524-5657. Please remember that you have a limited amount of time to take legal action and claims not filed within the statute of limitations are usually deemed to be barred. Thus, it is important that you talk to a qualified legal adviser as soon as possible.