Hendrix v. United Healthcare Insurance Company

Supreme Court of Alabama

Etowah County | No. 1190107 | Sept. 18, 2020


Medical Malpractice Claim was Preempted by ERISA and Properly Dismissed

Kathleen Hendrix, acting in her capacity as administratrix of the Estate of Kenneth Hendrix, appealed a judgment from the Etowah Circuit Court which dismissed her medical-malpractice wrongful-death claim against United Healthcare Insurance Company. Kenneth Hendrix was covered by a health-insurance policy issued by United.

He passed away after United declined to pay for a course of medical treatment recommended by his treating doctor. The trial court argued that Hendrix's claim was preempted by ERISA since the claim "related to" the ERISA-governed employee benefit plan from which United had issued Kenneth's health-insurance policy. The Supreme Court of Alabama upheld the judgment from the lower court, remarking that Hendrix's claim did have a connection to an ERISA-governed plan and was therefore defensively preempted.

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