Wood
v. Prudential Insur. Co. of America,
207 F.3d 674 (3rd Cir. 2000)-This
appeal addressed the doctrine of complete preemption.
This court found that ERISA completely
preempts a state law claim of discriminatory termination to avoid paying
benefits. Section 510 of ERISA provides a federal cause of action.
This is true even if the plaintiff prays for relief that 29 U.S.C. §
1132(a) does not provide. Wood sued his former employer for discriminatory termination,
defamation, and outrage, seeking compensatory damages, damages for humiliation,
pain and suffering, and punitive damages.
This
court noted that Wood, while seeking money damages for his allegedly improper
termination in his state claim, sought equitable damages for the same
termination in his federal ERISA claim. "Allowing
such parallel claims to be tried in both state and federal courts would
undermine Congress' choice of remedies as reflected in Section 502(a)."
This
court further explained the reasoning of complete preemption by turning to Ingersoll-Rand Co. v. McClendon, 498 U.S. 133, 143 (1990): "'The
policy choices reflected in the inclusion of certain remedies and the exclusion
of others under the federal scheme would be completely undermined if ERISA-plan
participants and beneficiaries were free to obtain remedies under state law that
Congress rejected in ERISA. The six
carefully integrated civil enforcement provisions found in § 502(a) of the
statute as finally enacted ... provide strong evidence that Congress did not
intend to authorize other remedies that it simply forgot to incorporate
expressly.'"