Studer v. Katherine Shaw Bethea Hospital

Dist. Ct. did not err in granting defendant-employer’s motion to remove to federal court plaintiff-employee’s state court Ill. Wage Payment and Collection Act action, alleging that defendant had failed to directly pay her money that had accrued in defendant’s Paid Days Leave plan, where plaintiff’s claim was completely preempted by ERISA. This is so, because: (1) plaintiff’s state-law claim could have been brought as claim under ERISA, since subject plan qualified as ERISA welfare benefit plan as funds in plan were used for qualifying medical expenses; and (2) defendant’s decision not to pay plaintiff funds in plan did not implicate legal duty independent of ERISA.