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.'"

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