APRIL 2009 BAD FAITH CASES
BAD FAITH CLAIM PREEMPTED BY ERISA (Philadelphia Federal)

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In Stout v. American Federation of State, County & Municipal Employees, the court found that the statutory bad faith claim was preempted by ERISA.

Date of Decision: January 21, 2009

Stout v. Am. Fed’n of State, County & Mun. Emples. Dist. Council 33, United States District Court, Eastern District of Pennsylvania, No. 08-4621, 2009 U.S. Dist. LEXIS 4198 (E.D.Pa. Jan. 21, 2009) (Schiller, J.)