Rush Prudential HMO, Inc. v. Moran

Rush Prudential HMO, Inc. v. Moran, 536 U.S. 355 (2002), was a decision by the Supreme Court of the United States, which ruled that the federal Employee Retirement Income Security Act (ERISA)[1] did not preempt an Illinois medical-review statute.[2]

Rush Prudential HMO, Inc. v. Moran
Argued January 16, 2002
Decided June 20, 2002
Full case nameRush Prudential HMO, Incorporated, Petitioner v. Debra C. Moran, et al.
Citations536 U.S. 355 (more)
122 S. Ct. 2151; 153 L. Ed. 2d 375; 2002 U.S. LEXIS 4644; 70 U.S.L.W. 4600; 27 Employee Benefits Cas. (BNA) 2921; 15 Fla. L. Weekly Fed. S 409
Case history
PriorMoran v. Rush Prudential HMO, Inc., No. 98-cv-442, 1999 WL 417384 (N.D. Ill. June 15, 1999); reversed, 230 F.3d 959 (7th Cir. 2000); cert. granted, 533 U.S. 948 (2001).
Court membership
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
David Souter · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Case opinions
MajoritySouter, joined by Stevens, O'Connor, Ginsburg, Breyer
DissentThomas, joined by Rehnquist, Scalia, Kennedy
Laws applied
Illinois's Health Maintenance Organization Act
Employee Retirement Income Security Act, 29 U.S.C. § 1001 et seq.

ERISA envisions a national standard for welfare and pension plans so state laws which "relate to" ERISA plans are preempted under Section 514 of ERISA. However, ERISA contains a "savings" clause which saves state laws which regulate insurance under Section 514(b). The statute at issue in Moran regulated insurance, which is one of the functions HMOs perform. Although HMOs provide healthcare as well as insurance, the statute does not require choosing a single or primary function of an HMO. Congress has long recognized that HMOs are risk-bearing organizations subject to state regulation. Finally, allowing States to regulate the insurance aspects of HMOs will not interfere with the desire of Congress for uniform national standards under ERISA.

See also

References

  1. 29 U.S.C. § 1001 et seq.
  2. Rush Prudential HMO, Inc. v. Moran, 536 U.S. 355 (2002).
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