Eid v. Duke’s Empirical Analysis

Citation profile

54 state decisions

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 54 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[h]aving preempted state law, ERISA provides specific remedies that are available in federal courts. ERISA has an “overpowering federal policy in [its] civil enforcement provisions. 29 U.S.C. § 1132 (a), authorizing civil actions for ... specific types of relief.” Rush Prudential HMO Inc. v. Moran, 536 U.S. 355 , 122 S.Ct. 2151, 2164 , 153 L.Ed.2d 375, 395 (2002) (footnote omitted). These provisions amount to an “interlocking, interrelated, and interdependent remedial scheme.” Massachusetts Mutual Life Ins. Co. v. Russell, 473 U.S. 134, 146 , 105 S.Ct. 3085, 3092 , 87 L.Ed.2d 96, 106 (1985). The United States Supreme Court has “been especially ‘reluctant to tamper with [the] enforcement scheme’ embodied in the statute by extending remedies not specifically authorized by its text.” Great-West Life & Annuity Ins. Co. v. Knudson, 534 U.S. 204, 209 , 122 S.Ct. 708, 712 , 151 L.Ed.2d 635, 642 (2002), quoting Massachusetts Mutual Life Ins. Co. v. Russell, supra, 473 U.S. at 147 , 105 S.Ct. at 3093 , 87 L.Ed.2d at 106 . State laws that provide alternative remedies are preempted under ERISA, as frustrating the purpose of ERISA of providing “a uniform judicial regime of categories of relief.” Rush Prudential HMO Inc. v. Moran, supra, 122 S.Ct. at 2169, 153 L.Ed.2d at 401 . See, e.g., Ingersoll-Rand Co. v. McClendon, 498 U.S. 133 , 111 S.Ct. 478 , 112 L.Ed.2d 474 (1990) (holding that Texas’s [sic] tort of wrongful discharge conflicted with ERISA enforcement by converting an equitable r”

   1 later decision quote this exact passage
   e.g. Robinette v. Hunsecker

2. ““The two motions for summary judgment in the case at bar were not based on separate and distinct grounds. Under circumstances like those in the present case, the issue of ERISA preemption is inextricably intertwined with the existence of a patient-physician relationship and whether the plaintiffs set forth a viable state law medical malpractice cause of action. As the Court of Special Appeals recognized ..., these issues are interrelated under the Supreme Court cases interpreting and applying the ERISA statute. In fact, the plaintiffs indirectly acknowledge that the issues are interrelated, as they repeatedly characterize their action as a medical malpractice action and rely on cases holding that ERISA does not preempt traditional state law medical malpractice actions.... ””

   1 later decision quote this exact passage
   e.g. Ross v. State Board of Elections

3. “safeguarding the interests of [employee benefit] plan participants and encouraging employers to offer such plans.” Eid v. Duke, 373 Md. 2, 11 , 816 A.2d 844, 849-50 (2003). ERISA sought to protect the interests of participants”

   1 later decision quote this exact passage
   e.g. Milliman, Inc. v. Maryland State Retirement & Pension System