Sixth Circuit Underscores ERISA’s Broad Preemptive Power in Patterson v. UnitedHealth Group

In Patterson v. UnitedHealth Grp., Inc., 161 F.4th 415 (6th Cir. 2025), the Sixth Circuit reinforced that ERISA broadly preempts state law claims, including post-payment reimbursement disputes.

In the Patterson case, plaintiff-appellant Eric Patterson argued that UnitedHealth Group, which insured his group benefit plan, wrongly required him to reimburse $25,000 from a settlement he received following a car accident, even though he later discovered that the plan document had no reimbursement provision. Id. at 419–20.

While Mr. Patterson initiated an ERISA lawsuit for equitable relief based on the reimbursement to the insurer, he separately filed a class action in Ohio state court alleging a variety of claims, including fraudulent misrepresentation, based on the same $25,000 reimbursement. Id. at 420. Following the removal of the class action, the Northern District of Ohio held that ERISA completely preempted the state law claims and dismissed the case. Id.

On appeal, the Sixth Circuit rejected the opposing approach of other Circuits, which suggested that post-payment reimbursement disputes fall outside ERISA’s enforcement provisions. The court then concluded that Mr. Patterson’s claims were preempted. In distinguishing those cases, the Sixth Circuit pointed out that those decisions involved situations where the insureds challenged their insurers’ reimbursement rights based on a state statute, whereas Mr. Patterson asserted that “his entitlement to benefits originate[d] with the ‘terms and conditions’ of his plan—not some freestanding source of state law.” Id. at 423–24.

In sum, although some Circuits have concluded differently, the Sixth Circuit has underscored ERISA’s “extraordinary pre-emptive power” and concluded that even post-payment disputes concerning reimbursement are essentially efforts to recover benefits due under ERISA. Id. at 421. For employers and insurers operating in the Sixth Circuit, this decision reinforces the idea that reimbursement provisions, and disputes arising from them, are governed by federal law and that state law claims in this space are likely to face preemption challenges.

If you have any questions about the application of ERISA’s extraordinary pre-emptive power, please contact Olivia L. Southam or any member of the Frantz Ward Litigation practice group.