Metropolitan Life Ins. Co. v. Taylor

In Metropolitan Life Ins. Co. v. Taylor, 481 U.S. 58, 107 S.Ct. 1542, 1546, 95 L.Ed.2d 55 (1987), in which the plaintiffs filed state common law causes of action in a state court asserting improper processing of a claim for benefits under a plan regulated by ERISA. The Court framed the issue as whether these state common law claims are not only pre-empted by ERISA, but also displaced by ERISA's civil enforcement provision, Sec. 502(a)(1)(B), 29 U.S.C. Sec. 1132(a)(1)(B), to the extent that complaints filed in state courts purporting to plead such state common law causes of action are removable to federal court under 28 U.S.C. Sec. 1441(b). 107 S.Ct. at 1544-45. The Court held that state law causes of action that came within the scope of section 502(a) of ERISA were removable. At the same time, however, the Court made clear its determination to limit the application of the complete preemption doctrine. Even in the context of a statute like ERISA with its "unique preemptive force" and its civil enforcement provision creating a federal cause of action "that lies at the heart of the statute," the Court declared itself "reluctant to find that extraordinary pre-emptive power" necessary for the complete preemption doctrine to apply "in the absence of explicit direction from Congress." Id. at 1547. This reluctance was overcome in Metropolitan Life only because Congress had manifested a "clear intention to make Sec. 502(a)(1)(B) suits brought by ERISA participants or beneficiaries federal questions for purposes of federal court jurisdiction in like manner as Sec. 301 of the LMRA." Id. at 1547. The Court found such an explicit intention both from the fact that ERISA's civil enforcement provisions closely parallel those of Sec. 301 of the LMRA and from the following "specific reference to the Avco rule" in the ERISA Conference Report: All such actions in Federal or State courts are to be regarded as arising under the laws of the United States in similar fashion to those brought under section 301 of the Labor-Management Relations Act of 1947. H.R.Conf.Rep. No. 93-1280, p. 327 (1974) (Id. at 1547.) The Court held as follows: Congress has clearly manifested an intent to make causes of action within the scope of the civil enforcement provisions of Sec. 502(a) removable to federal court. Since we have found Taylor's cause of action to be within the scope of Sec. 502(a), we must honor that intent whether pre-emption was obvious or not at the time this suit was filed. Accordingly, this suit, though it purports to raise only state law claims, is necessarily federal in character by virtue of the clearly manifested intent of Congress. Id. at 1548. Justice Brennan, joined by Justice Marshall, embraced the opinion of the Court but wrote separately to emphasize that the relevant congressional intent was not an intent that the statute should displace state law, but rather an intent that claims purportedly based on state law be removable: While I join the Court's opinion, I note that our decision should not be interpreted as adopting a broad rule that any defense premised on congressional intent to preempt state law is sufficient to establish removal jurisdiction. The Court holds only that removal jurisdiction exists when, as here, "Congress has clearly manifested an intent to make causes of action ... removable to federal court." Ibid (emphasis added). In future cases involving other statutes, the prudent course for a federal court that does not find a clear congressional intent to create removal jurisdiction will be to remand the case to state court. Id. at 1548 (Brennan, J., concurring).