Rush Prudential HMO, Inc. v. Moran
| Rush Prudential HMO, Inc. v. Moran | |
|---|---|
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| Argued January 16, 2002 Decided June 20, 2002 | |
| Full case name | Rush Prudential HMO, Incorporated, Petitioner v. Debra C. Moran, et al. |
| Citations | 536 U.S. 355 (more) 122 S. Ct. 2151; 153 L. Ed. 2d 375; 2002 U.S. LEXIS 4644; 70 U.S.L.W. 4600; 27 Employee Benefits Cas. (BNA) 2921; 15 Fla. L. Weekly Fed. S 409 |
| Case history | |
| Prior | Moran v. Rush Prudential HMO, Inc., No. 98-cv-442, 1999 WL 417384 (N.D. Ill. June 15, 1999); reversed, 230 F.3d 959 (7th Cir. 2000); cert. granted, 533 U.S. 948 (2001). |
| Holding | |
| ERISA did not preempt an Illinois medical-review statute. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Souter, joined by Stevens, O'Connor, Ginsburg, Breyer |
| Dissent | Thomas, joined by Rehnquist, Scalia, Kennedy |
| Laws applied | |
| Illinois's Health Maintenance Organization Act Employee Retirement Income Security Act | |
Rush Prudential HMO, Inc. v. Moran, 536 U.S. 355 (2002), was a decision by the Supreme Court of the United States in which the court held that the federal Employee Retirement Income Security Act (ERISA) did not preempt an Illinois medical-review statute.[1][2][3]
ERISA envisions a national standard for welfare and pension plans so state laws which "relate to" ERISA plans are preempted under Section 514 of ERISA. However, ERISA contains a "savings" clause which saves state laws which regulate insurance under Section 514(b). The statute at issue in Moran regulated insurance, which is one of the functions HMOs perform. Although HMOs provide healthcare as well as insurance, the statute does not require choosing a single or primary function of an HMO. Congress has long recognized that HMOs are risk-bearing organizations subject to state regulation. Finally, allowing States to regulate the insurance aspects of HMOs will not interfere with the desire of Congress for uniform national standards under ERISA.
This case was partially overruled in Kentucky Ass'n of Health Plans, Inc. v. Miller, 538 U.S. 329 (2003).
References
- ↑ Rush Prudential HMO, Inc. v. Moran, 536 U.S. 355 (2002).
- ↑ Reinhart, Stephanie (January 1, 2004). "Rush Prudential HMO, Inc. v. Moran: 21 or Bust! Does ERISA Preemption Give HMOs the Power to Gamble with Our Health?". Akron Tax Journal. 19 (1). ISSN 0002-371X.
- ↑ Berman-Sandler, Leatrice (January 1, 2004). "Independent Medical Review: Expanding Legal Remedies to Achieve Managed Care Accountability". Annals of Health Law and Life Sciences. 13 (1): 233. ISSN 1075-2994.
External links
- Text of Rush Prudential HMO, Inc. v. Moran, 536 U.S. 355 (2002) is available from: CourtListener Google Scholar Internet Archive (docket files) Justia Library of Congress Oyez (oral argument audio)
- United States Supreme Court cases
- United States Supreme Court cases of the Rehnquist Court
- Employee Retirement Income Security Act of 1974 case law
- United States Supreme Court cases in 2002
- Prudential Financial
- United States field preemption case law
- United States Supreme Court cases of the Rehnquist Court stubs
