Metropolitan Life Ins. Co. v. Taylor
Citation and Court
481 U.S. 58 (1987) — Supreme Court of the United States
Facts
Gerald Taylor sued his employer’s insurer, Metropolitan Life, in Michigan state court for wrongful termination of disability benefits, asserting state-law contract and tort claims. Metropolitan Life removed the case to federal court on the ground that ERISA completely preempted the state claims and converted them into federal claims. Taylor moved to remand.
Issue
Whether ERISA so completely preempts state-law claims relating to employee benefit plans that such claims are recharacterized as federal claims and subject to removal even when the plaintiff pleads only state-law causes of action.
Holding
Yes. ERISA’s civil enforcement provisions so completely preempt state-law claims within their scope that such claims are necessarily federal in character and removable to federal court regardless of how the plaintiff frames the complaint.
Rule / Doctrine
Complete preemption doctrine extended to ERISA: when Congress has completely displaced state law in a given area — as it did in ERISA’s civil enforcement provisions — a state claim falling within that area is recharacterized as federal law and arises under federal law for purposes of removal jurisdiction, even if the complaint pleads only state causes of action.
Significance
Taylor is the leading case extending the Avco complete preemption doctrine to ERISA. It establishes that certain federal statutory schemes so thoroughly occupy a field that federal jurisdiction is proper regardless of plaintiff’s pleading strategy, and it remains the primary vehicle through which ERISA benefit disputes are channeled into federal court.