APRIL 2015 BAD FAITH CASES: BAD FAITH CLAIM PREEMPTED BY ERISA AS TO INSURER (Middle District)

In the court’s first decision in Hayes v. Reliance Standard Life Insurance Company, the insured’s bad faith claim against the insurer was preempted by ERISA.  Six days later, the same argument failed as to a claim against an insurance broker, as insufficiently related to the plan at issue.

Date of Decision:  March 17, 2015 and March 23, 2015

Hayes v. Reliance Std. Life Ins. Co., CIVIL ACTION NO. 3:14-0714, 2015 U.S. Dist. LEXIS 32543 (M.D. Pa. March 17, 2015) (Mannion, J.)

Hayes v. Reliance Std. Life Ins. Co., CIVIL ACTION NO. 3:14-0714, 2015 U.S. Dist. LEXIS 35682 (M.D. Pa. March 23, 2015) (Mannion, J.)