Wednesday, February 20, 2008|
Supreme Court rules in preemption, ERISA retirement plan cases
Jeannie Shawl at 10:24 AM ET
[JURIST] The US Supreme Court [official website; JURIST news archive] handed down decisions in five cases Wednesday, including Rowe v. New Hampshire Motor Transport Association [LII case backgrounder; JURIST report], where the Court held that federal law preempts two provisions of a Maine tobacco transport law requiring special inspection of incoming tobacco packages to prevent purchases from unlicensed retailers who might sell to minors. The Court affirmed the First Circuit's decision [text] in the case, and ruled that the Federal Aviation Administration Authorization Act of 1994 (FAAAA) [text], which limits state regulation of interstate air and motor carriers, preempts the two Maine law provisions. Read the Court's opinion [text] per Justice Breyer, along with a concurrence [text] from Justice Ginsburg and a second concurrence [text] from Justice Scalia. AP has more.
In Preston v. Ferrer [LII case backgrounder] the Court ruled that the Federal Arbitration Act [text] preempts a state statute which requires administrative review before a contract dispute can proceed to arbitration. The Court reversed the California Court of Appeals' decision in the case, and held that "when parties agree to arbitrate all questions arising under a contract, state laws lodging primary jurisdiction in another forum, whether judicial or administrative, are superseded by the FAA." Read the Court's opinion [text] per Justice Ginsburg, along with a dissent [text] from Justice Thomas. AP has more.
In a third preemption case, the Court held in Riegel v. Medtronic [LII case backgrounder] that the preemption clause found in the federal Medical Device Amendments of 1976 prevents a patient whose catheter ruptured during surgery from suing the manufacturer based on state common law claims. Charles Riegel filed a lawsuit against Medtronic on multiple claims based on New York common law, but the Supreme Court affirmed the Second Circuit's decision [PDF text] that the MDA preempts claims under state law. Read the Court's opinion [text] per Justice Scalia, along with a concurrence [text] from Justice Stevens and a dissent [text] from Justice Ginsburg. AP has more.
In LaRue v. DeWolff, Boberg & Associates [LII case backgrounder; JURIST report] the Court held that the Employee Retirement Income Security Act (ERISA) [text; US DOL backgrounder] allows an employee to sue for losses incurred when administrators of his retirement plan ignore his instructions on how to invest his retirement money:
We therefore hold that although §502(a)(2) does not provide a remedy for individual injuries distinct from plan injuries, that provision does authorize recovery for fiduciary breaches that impair the value of plan assets in a participant's individual account.The Court vacated and remanded the Fourth Circuit's decision [PDF text] in the case. Read the Court's opinion [text] per Justice Stevens, along with a concurrence [text] from Chief Justice Roberts and a second concurrence [text] from Justice Thomas. AP has more.
Finally, in Danforth v. Minnesota [Duke Law case backgrounder] the Court held that state courts are not bound by the same standard as federal courts in Teague v. Lane [text] in determining whether US Supreme Court decisions apply retroactively to state court criminal cases. In reversing the Minnesota Supreme Court's decision in the case, the US Supreme Court wrote:
New constitutional rules announced by this Court that place certain kinds of primary individual conduct beyond the power of the States to proscribe, as well as "watershed" rules of criminal procedure, must be applied in all future trials, all cases pending on direct review, and all federal habeas corpus proceedings. All other new rules of criminal procedure must be applied in future trials and in cases pending on direct review, but may not provide the basis for a federal collateral attack on a state-court conviction. This is the substance of the "Teague rule" described by Justice O'Connor in her plurality opinion in Teague v. Lane, 489 U. S. 288 (1989). The question in this case is whether Teague constrains the authority of state courts to give broader effect to new rules of criminal procedure than is required by that opinion. We have never suggested that it does, and now hold that it does not.Read the Court's opinion [text] per Justice Stevens, along with a dissent [text] from Chief Justice Roberts. AP has more.
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