Lordmann Enterprises, Inc. v. Equicor, Inc.’s Empirical Analysis
32 F.3d 1529 · 1994
Citation profile
14 federal appellate · 7 district · 9 state decisions
How this case has been cited
Cited by 112 later decisions — most recently May 2024 · most notably Butero v. Royal Maccabees Life Insurance (1999), Morstein v. National Insurance Services, Inc. (1996)
14 federal appellate · 7 district · 9 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 29 U.S.C. § 1001 (§ 2 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1002 (§ 3 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1132 (§ 502 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1144 (§ 514 of the Employee Retirement Income Security Act of 1974)
Relies on Celotex Corporation v. Catrett H · United States v. Diebold, Inc. · Firestone Tire and Rubber Company v. Bruch · Shaw v. Delta Air Lines, Inc. · American Manufacturers Mutual Insurance v. United States
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 112 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[Plaintiff] is suing [the insurer] with respect to its pre-plan activity in its role as a seller of insurance, not as an administrator of an employee benefits plan .... Of the four principal ERISA entities, the employer, the plan, the beneficiaries, and the plan fiduciaries, [the insurer] could only claim to be the last. However, Congress quite logically defined a plan fiduciary in relation to a plan. If no plan exists, by definition plan fiduciaries cannot exist.... That [the insurer) may have later acted as a plan fiduciary does not alter its pre-plan status.... Allowing [plaintiff's] claims to proceed is consistent with Congress' purpose in enacting ERISA, that is, to protect the interests of employees and other beneficiaries of benefit plans and establish uniform standards regulating such plans. Holding in-swrers accountable for pre-plan fraud does not affect the administration or calculation of benefits, nor does it alter the required duties of plan fiduciaries .... Conversely, were ERISA to preempt such claims, - "employees, whom - Congress sought to protect, [would] find themselves unable to make informed choices regarding available benefit plans." ... We agree with the Eighth Cireuit ... that a state's "efforts to prevent sellers of goods and services, including benefit plans, from misrepresenting ... the scope of their services is 'quite remote from the area with which ERISA is expressly concerned-reporting, disclosure, fiduciary responsibility and the like'" [quotin”
1 later decision quote this exact passage · from the majority“The breadth of [§ 1144(a)’s] pre-emptive reach is apparent from that section’s language. A law “relates to” an employee benefit plan, in the normal sense of the phrase, if it has a connection with or reference to such a plan.”
1 later decision quote this exact passage · from the majority“[t]he `commercial realities' of the health care industry require that health care providers be able to rely on insurers' representations as to coverage.”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.