State health plan reporting
Gobeille v. Liberty Mutual Insurance
In brief
ERISA overrides Vermont’s claims-data reporting law for ERISA plans, and the Supreme Court left the Second Circuit’s ruling in place.
- Where it stands
- Decided
Decided 6-2 · March 1, 2016 · Opinion by Justice Kennedy
- What it’s about
- Vermont required health plans, including Liberty Mutual’s self-insured employee plan, to report claims data to the state; Liberty Mutual challenged the rule under the federal Employee Retirement Income Security Act (ERISA).
- Who it affects
- Vermont cannot apply this reporting requirement to employee benefit plans governed by ERISA, including Liberty Mutual’s self-insured plan.
Summary: written with AI from the case record.
What it's about
The Supreme Court agreed with the lower court (affirmed) and decided that ERISA overrides Vermont’s reporting law as applied to ERISA plans.
Justice Breyer noted that Liberty Mutual’s self-insured plan provided benefits to more than 80,000 people living in 50 states.
Vermont created a state database to collect health claims information and track the care residents received and its cost.
Question presented
Do the reporting requirements of the Employee Retirement Income Security Act of 1974 preempt a Vermont state statute regarding reporting requirements as applied to a self-insured employee health plan?
What the Court decided
Holding
ERISA pre-empts Vermont’s statute as applied to ERISA plans. 746 F. 3d 497, affirmed.
- Result
- Affirmed
The vote
- Joined the judgment
- Concurred in a separate opinion
- Dissented
- Wrote an opinion
- Concurring · 2agreed with the result, wrote separately
- Breyerwrote separately
- Thomaswrote separately
- Dissenting · 2disagreed with the result
- Ginsburgwrote the dissent
- Sotomayor
From the opinions
“I would hold that Vermont’s effort to track health care services provided to its residents and the cost of those services does not impermissibly intrude on ERISA’s dominion over employee benefit plans.”
What's next
The Second Circuit’s ruling remains in force, so Vermont cannot apply the reporting requirement to ERISA plans. The Supreme Court did not send the case back to a lower court.
Documents
Opinions
Docket activity
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Case Briefing
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AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Opinion added: Gobeille
More questions
- Why did Justice Breyer write separately?
- He warned that state reporting rules could leave self-insured ERISA plans facing 50 or more conflicting demands, causing administrative problems, confusion and added costs.
- What did Justice Thomas say?
- Thomas said he joined the Court’s opinion but questioned whether Congress had power to make ERISA override state laws so broadly and whether the Court’s approach fit its other cases.
- Why did Justice Ginsburg disagree?
- She argued that Vermont’s effort to track health services and costs did not improperly intrude on federal regulation of employee benefit plans.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.