Hobson v. Robinson’s Empirical Analysis
2003
Citation profile
2 federal appellate · 1 district · 1 state decisions
Relationships
Applies 29 U.S.C. § 1001 (§ 2 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 Shaw v. Delta Air Lines, Inc. · Pilot Life Insurance v. Dedeaux · Ingersoll-Rand Co. v. McClendon · New York State Conference of Blue Cross & Blue Shield Plans v. Travelers Insurance · Fort Halifax Packing Co. v. Coyne
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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he critical determination [is] whether the claim itself created a relationship between the plaintiff and defendant that is so intertwined with an ERISA plan that it cannot be separated.”
3 later decisions quote this exact passage · from the majority“[o]ur decisions since Perkins have reaffirmed that the important factor in ERISA preemption is the relationship between the parties involved in the claim itself and whether that claim is intricately bound with an ERISA plan ... [t]he critical factor was that the fraudulent inducement claim did not require interpretation and administration of the ERISA policy ... [here], Hobson’s claims for fraud and misrepresentation do not require interpretation or administration of the ERISA plan ... Hobson’s claims are based upon benefits given up for purposes of ERISA and thus are not preempted by ERISA ... Joe Chrest-man, like the agent in Perkins ... allegedly fraudulently induced Hobson to surrender his pre-existing insurance coverage in order to obtain an ERISA plan. Joe Chrestman’s underlying conduct relates only indirectly to the ERISA plan. As such, the relationship between Hobson and Joe Chrestman derives from state common-law claims, not the ERISA plan. Moreover, this conclusion does not contradict Congress’s intent in enacting ERISA-the simplification of plan interpretation and administration-because Hobson’s claims do not require either plan interpretation or administration.”
1 later decision quote this exact passage · from the majoritye.g. McMurtry v. Wiseman“[TJhis Court applies a two-prong test; that is, this Court asks: (1) whether the claim addresses areas of exclusive federal concern and not of traditional state authority, such as the right to receive benefits under the terms of an ERISA plan, and (2) whether the claim directly affects the relationship among traditional ERISA entities — the employer, the plan and its fiduciaries, and the participants and beneficiaries.”
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.