In Corcoran v. United Healthcare, Inc., 965 F.2d 1321 (5th Cir.), cert. denied, U.S. 113 S.Ct. 812, 121 L.Ed.2d 684 (1992), an ERISA-plan participant sued United Healthcare, which performed utilization review for the plan, for wrongful death of an unborn child. On the basis of the utilization review, plaintiff was denied authorization for hospitalization and lost her fetus. Id. at 1324. The Fifth Circuit held that ERISA preempted the state tort claim because United Healthcare was determining the availability of benefits under the plan. Id. at 1331.