Suvarna Garge (Editor)

Rush Prudential HMO, Inc. v. Moran

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End date
  
2002

Full case name
  
Rush Prudential HMO, Incorporated, Petitioner v. Debra C. Moran, et al.

Citations
  
536 U.S. 355 (more) 122 S. Ct. 2151; 153 L. Ed. 2d 375; 2002 U.S. LEXIS 4644; 70 U.S.L.W. 4600; 27 Employee Benefits Cas. (BNA) 2921; 15 Fla. L. Weekly Fed. S 409

Prior history
  
On writ of certiorari to the United States Court of Appeals for the Seventh Circuit

Majority
  
Souter, joined by Stevens, O'Connor, Ginsburg, Breyer

Dissent
  
Thomas, joined by Rehnquist, Scalia, Kennedy

Rush Prudential HMO, Inc. v. Moran, 536 U.S. 355 (2002) was a decision by the Supreme Court of the United States, which ruled that the federal Employee Retirement Income Security Act (ERISA) did not preempt an Illinois medical-review statute.

ERISA envisions a national standard for welfare and pension plans so state laws which "relate to" ERISA plans are preempted under Section 514 of ERISA. However, ERISA contains a "savings" clause which saves state laws which regulate insurance under Section 514(b). The statute at issue in Moran regulated insurance, which is one of the functions HMOs perform. Although HMOs provide healthcare as well as insurance, the statute does not require choosing a single or primary function of an HMO. Congress has long recognized that HMOs are risk-bearing organizations subject to state regulation. Finally, allowing States to regulate the insurance aspects of HMOs will not interfere with the desire of Congress for uniform national standards under ERISA.

References

Rush Prudential HMO, Inc. v. Moran Wikipedia