Sixth Circuit Holds ERISA Completely Preempts State-Law Claims Challenging Insurer’s Reimbursement Practices

In Patterson v. UnitedHealth Group, Inc., No. 25-3175, —F.4th—-, 2025 WL 3458953 (6th Cir. Dec. 2, 2025), the Sixth Circuit affirmed the dismissal of a putative class action alleging that UnitedHealth and related entities improperly collected reimbursement from a plan participant based on a summary plan description that conflicted with the undisclosed governing plan document. Although the plaintiff pleaded only state-law claims—including fraud, negligent misrepresentation, conversion, unjust enrichment, and civil conspiracy—the court held that ERISA’s “extraordinary pre-emptive power” converted those claims into federal claims under ERISA § 502(a). Because the plaintiff already had a parallel ERISA action pending over the same conduct, the court allowed dismissal of the duplicative suit.

Background

Patterson and his wife were covered by an ERISA-governed health plan administered by UnitedHealth. After each sustained injuries in automobile accidents, UnitedHealth paid their medical expenses but—based on the summary plan description (SPD)—asserted a right to reimbursement from any third-party recovery.

For Mr. Patterson, United claimed reimbursement rights, and he repaid $25,000 following his tort settlement. For Mrs. Patterson, United later produced the full plan document, which stated it controlled over the SPD and contained no reimbursement provision. State courts ultimately held that the plan did not grant United reimbursement rights.

Armed with the actual plan terms, Patterson filed an ERISA action seeking equitable relief for the alleged misrepresentations and improper reimbursement. While that federal action was pending on appeal, he refiled his state-law claims in state court. Defendants removed, asserting complete preemption.

Complete Preemption Under ERISA § 502(a)

The Sixth Circuit applied the two-part test from Aetna Health Inc. v. Davila, 542 U.S. 200 (2004) and held that ERISA completely preempted Patterson’s state-law theories.

1. Prong One – Could the claim have been brought under § 502(a)?

Yes. Patterson’s state-law theories were, “in essence,” claims to recover benefits wrongfully taken via reimbursement. Misapplication of the plan’s terms allegedly diminished the benefits he should have received “free and clear.” The court emphasized that other circuits uniformly hold that state-law challenges to ERISA reimbursement are disguised § 502(a)(1)(B) claims. Patterson had already asserted—and then disavowed—a § 502(a)(1)(B) claim on the same facts in his earlier federal suit. The fact that benefits had been paid but later clawed back does not avoid preemption. Benefits subject to reimbursement remain “under a cloud.”

2. Prong Two – Is there an independent legal duty?

No. Although couched in general common-law duties (fraud, misrepresentation, conversion), each alleged wrong depended entirely on the plan’s terms—specifically, whether the plan allowed reimbursement and whether defendants misstated the plan’s content. Determining liability required interpreting the ERISA plan.

The court distinguished Wurtz v. Rawlings Co., 761 F.3d 232 (2d Cir. 2014), noting that Patterson did not rely on any independent state statute but on rights derived solely from plan terms.

Dismissal Permitted Due to Claim-Splitting

Although complete preemption typically results in recharacterizing claims as ERISA causes of action, the district court dismissed the case outright because Patterson already had a pending ERISA action asserting § 502(a)(3) claims based on the same facts. He had previously disclaimed a § 502(a)(1)(B) theory and could not revive it and permitting repleading would result in duplicative litigation. The Sixth Circuit affirmed, recognizing the district court’s discretion to prevent claim-splitting and manage duplicative suits.