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.)