Complete ERISA Preemption of State-Law Reimbursement and Fraud Claims

A Detailed Commentary on Eric L. Patterson v. UnitedHealth Group, Inc., et al., No. 25-3175 (6th Cir. Dec. 2, 2025)

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I. Introduction

This appeal sits at the intersection of ERISA’s powerful preemption regime, health-plan reimbursement provisions, and plaintiffs’ efforts to reframe benefit disputes as state-law fraud and restitution claims. The Sixth Circuit’s decision in Patterson v. UnitedHealth Group, Inc. clarifies how broadly ERISA’s “complete preemption” doctrine sweeps in reimbursement disputes—even where the plan has already paid medical benefits and later seeks to recoup them—and confirms that fraud-based claims tied to plan terms are not “independent” of ERISA for purposes of the Supreme Court’s Aetna Health Inc. v. Davila test.

The case arises from a long-running dispute between Eric Patterson, a participant in an ERISA-governed employer health plan sponsored by Swagelok Company, and UnitedHealth Group and its affiliates (collectively “United”), which insured and administered the plan. At its core, Patterson contends that United misled him into reimbursing the plan $25,000 from his tort recovery for injuries he sustained in a motor-vehicle accident, even though the full plan document (later produced in his wife’s related case) contained no reimbursement provision and superseded the summary plan description (SPD) on which United had relied.

Patterson has already litigated an ERISA action in federal court (his “first” federal suit), obtained a partial reversal on appeal, and is currently pursuing an equitable relief claim under ERISA § 502(a)(3). While that first appeal was pending, he filed a separate putative class action in Ohio state court alleging state-law causes of action—fraudulent and negligent misrepresentation, conversion, unjust enrichment, and civil conspiracy—based on the same $25,000 reimbursement episode. Defendants removed, invoking complete preemption under ERISA § 502(a), and sought dismissal as duplicative. The district court denied remand, held the state claims completely preempted, and dismissed the case as a duplicative ERISA action.

On appeal, Patterson challenged both removal (arguing his claims were independent state-law torts) and dismissal. The Sixth Circuit affirmed in full. In doing so, it:

• Applied Davila’s two-prong test to hold that Patterson’s state-law reimbursement and fraud-based claims are completely preempted by ERISA § 502(a)(1)(B),
• Rejected the plaintiff’s argument that post-payment reimbursement disputes fall outside ERISA’s benefit-enforcement rubric, aligning with several other circuits and distancing itself from the Second Circuit’s approach in Wurtz v. Rawlings Co., and
• Approved the district court’s discretionary dismissal of the removed action as a duplicative ERISA lawsuit in light of Patterson’s prior disavowal of a § 502(a)(1)(B) claim and his existing § 502(a)(3) case.

The opinion is “recommended for publication,” making it binding precedent in the Sixth Circuit and a significant authority in ERISA litigation involving plan reimbursement and state-law tort framing.

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II. Case Background

A. The Underlying Health Plan and Reimbursement Dispute

Patterson and his wife were covered under an ERISA-governed group health plan sponsored by his employer, Swagelok Company. UnitedHealth and its affiliates insured and administered the plan. As ERISA requires, United provided a summary plan description. However, Patterson did not initially receive the full plan document. Under ERISA, the SPD is meant to summarize plan terms, but it is the formal plan document that ultimately controls if there is a conflict.

The SPD stated that if a participant recovered from a third party (e.g., a tortfeasor) for an injury for which the plan had paid medical benefits, the plan had reimbursement rights against that recovery. That reimbursement language became crucial when:

• Patterson was injured in a collision with a semi-truck,
• United, via its subsidiary Optum, paid his medical expenses, and
• Optum notified Patterson that it would seek reimbursement out of any recovery he obtained from the other driver.

Patterson sued the other driver’s employer in state court and, in the same suit, sought declaratory relief against the plan on reimbursement. During that litigation, he alleged that United falsely claimed no full plan document existed. Ultimately, he settled with the tortfeasor’s employer and agreed to reimburse the plan $25,000 from the settlement.

B. The Parallel Case Involving Mrs. Patterson and the Missing Plan Document

Shortly afterward, Patterson’s wife was injured in a separate accident. The pattern repeated:

• United paid her medical expenses,
• Optum asserted reimbursement rights, and
• Ms. Patterson sued the other driver in state court and sought a declaratory judgment on the plan’s reimbursement rights.

This second case produced a key development: United produced the full plan document in discovery, having previously claimed (in Mr. Patterson’s litigation) that no such document existed. The full plan document explicitly stated that it controlled over the SPD in the event of any inconsistency. Crucially, unlike the SPD, the plan document contained no reimbursement provision at all.

On that basis, the Ohio state court granted declaratory relief in Ms. Patterson’s favor, holding that the plan did not grant United reimbursement rights. The Ohio Court of Appeals affirmed in Patterson v. American Family Insurance Co., 178 N.E.3d 573, 581 (Ohio Ct. App. 2021).

C. The First Federal ERISA Action

Armed with the newly unearthed plan document and the state declaratory judgment, Patterson filed a federal suit under ERISA’s civil enforcement provision, 29 U.S.C. § 1132(a) (also referred to as ERISA § 502(a)), against United, Optum, Swagelok, and others. He alleged that defendants had defrauded him into paying the $25,000 reimbursement that the plan did not authorize.

In that first federal case:

• The district court dismissed for lack of standing and failure to state a claim. Patterson v. UnitedHealthcare Ins. Co. (Patterson I), 2022 WL 279952 (N.D. Ohio Jan. 31, 2022).
• On appeal, the Sixth Circuit “mostly affirmed” but revived Patterson’s § 502(a)(3) claim, allowing an equitable ERISA claim to proceed. Patterson v. United Healthcare Ins. Co., 76 F.4th 487, 500 (6th Cir. 2023).
• That revived § 502(a)(3) claim remains pending in the district court on remand. See Patterson v. UnitedHealthcare Ins. Co. (Patterson II), 762 F. Supp. 3d 643, 666 (N.D. Ohio 2025).

Notably, in that first appeal the Sixth Circuit found that Patterson had “disavowed” reliance on ERISA § 502(a)(1)(B), the provision authorizing suits to “recover benefits due” and “to enforce” rights under the plan’s terms.

D. The Second (State-Law) Class Action and Removal

While the first federal appeal was pending, the district court declined supplemental jurisdiction over Patterson’s state-law claims. He then refiled those claims in Ohio state court, naming United, Optum, and Swagelok as defendants and purporting to represent two classes. His causes of action included:

• Fraudulent misrepresentation,
• Negligent misrepresentation,
• Conversion,
• Unjust enrichment, and
• Civil conspiracy.

All rested on the same factual nucleus as the ERISA case—the allegedly improper $25,000 reimbursement obtained via a misleading SPD and misrepresentations about the existence and content of the full plan document.

Defendants removed the case to federal court, invoking ERISA’s “complete preemption” doctrine as a basis for federal question jurisdiction under 28 U.S.C. § 1331. They then moved to dismiss on the ground that the lawsuit was duplicative of the pending ERISA case. Patterson moved to remand, insisting his claims were independent state torts that could coexist with his ERISA action.

The district court:

• Denied the motion to remand, holding that ERISA completely preempted the state-law claims under § 502(a)(3), and
• Dismissed the action as duplicative of the first ERISA suit, in which his § 502(a)(3) claim was already proceeding.

Patterson again appealed, challenging both the preemption ruling and the dismissal.

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III. Summary of the Sixth Circuit’s Opinion

The Sixth Circuit (Judge Readler, joined by Judges Siler and Nalbandian) affirmed the district court’s judgment in all respects. The key holdings are:

1. Complete Preemption Applies Under Davila’s Two-Prong Test.
   • The court reaffirmed that ERISA’s civil enforcement provision, § 502(a), has “extraordinary pre-emptive power” that can transform state-law claims into federal ones for jurisdictional purposes.
   • Applying Aetna Health Inc. v. Davila, 542 U.S. 200 (2004), it held that:
     • (1) Patterson’s state-law claims are “in essence” an attempt to “recover benefits due” or “enforce rights” under the plan within the meaning of § 502(a)(1)(B), and
     • (2) The alleged duties (no fraud, no conversion, etc.) are not “independent” of ERISA or the plan terms because they derive from, and cannot be evaluated without interpreting, the plan’s terms on reimbursement.
2. Reimbursement Clawback Disputes Are § 502(a)(1)(B) Claims.
   • Even though the plan initially paid Patterson’s medical bills, United’s later demand for reimbursement effectively diminished his benefits.
   • The court aligned itself with multiple circuits (Third, Fourth, Fifth, Ninth) that treat state-law challenges to ERISA-plan reimbursement demands as § 502(a)(1)(B) actions for “benefits due.”
   • The court declined to follow the Second Circuit’s narrower view in Wurtz v. Rawlings Co., 761 F.3d 232 (2d Cir. 2014), which had placed greater emphasis on the state-law label and statutory basis of the claim.
3. Fraud, Conversion, Unjust Enrichment, and Conspiracy Claims Are Not Independent of the Plan.
   • Each cause of action presupposes that the plan did not grant United reimbursement rights; otherwise, there would be no falsity, “wrongful” taking, unjust enrichment, or actionable conspiracy.
   • Because resolving those issues requires interpretation of the ERISA plan, these tort duties are only “nominally” independent and therefore satisfy Davila’s second prong for complete preemption.
4. District Court’s Dismissal of the Removed Action Was Proper.
   • Although complete preemption usually results in recharacterizing state-law claims as ERISA § 502(a) claims rather than dismissing them, the district court had discretion here to dismiss the action as duplicative.
   • Patterson had previously “disavowed” a § 502(a)(1)(B) claim in his first appeal and thus could not resurrect it in this second action.
   • His § 502(a)(3) claim is already being litigated in the first federal suit; allowing a second case premised on the same facts and theory would amount to improper claim-splitting.

In sum, the Sixth Circuit both confirms the breadth of ERISA complete preemption in reimbursement disputes and underscores courts’ authority to dismiss later-filed, duplicative ERISA actions, particularly where plaintiffs have already chosen—and then narrowed—their ERISA remedies.

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IV. Detailed Analysis

A. Precedents and Authorities Cited

1. The Supreme Court’s ERISA Preemption Framework

The opinion rests on a cluster of Supreme Court decisions defining ERISA preemption and federal-question jurisdiction:

• Well-Pleaded Complaint Rule — The baseline rule is that federal jurisdiction under 28 U.S.C. § 1331 exists only if a federal question appears on the face of the plaintiff’s complaint. See Taylor v. Anderson, 234 U.S. 74 (1914).
• Metropolitan Life Insurance Co. v. Taylor, 481 U.S. 58 (1987) — Taylor recognized that some federal statutes have such powerful preemptive force that state-law claims falling within them are “recharacterized” as federal claims for jurisdictional purposes. ERISA § 502(a) is one of those provisions.
• Aetna Health Inc. v. Davila, 542 U.S. 200 (2004) — Davila articulates the now-standard two-prong test for ERISA complete preemption:
  1. The plaintiff could have brought his claim under ERISA § 502(a), and
  2. No other, independent legal duty is implicated by the defendant’s actions.
  Claims satisfying both prongs “fall within the scope” of § 502(a) and are completely preempted.
• Gobeille v. Liberty Mutual Insurance Co., 577 U.S. 312 (2016) — Cited in passing to note that even the presumption against preemption in “traditional state regulation” has been questioned in the ERISA context (though that discussion primarily related to “express preemption,” not complete preemption).
• N.Y. State Conference of Blue Cross & Blue Shield Plans v. Travelers Insurance Co., 514 U.S. 645 (1995) — Relied upon by Patterson to argue that fraud regulation is a traditional state function, but distinguished by the Sixth Circuit given the different focus (express preemption under § 514 rather than complete preemption under § 502(a)).

2. Sixth Circuit’s Own Precedent on Complete vs. Express Preemption

The panel carefully distinguishes between:

• Complete preemption (a jurisdictional doctrine) and
• Express preemption (a substantive defense under § 514, 29 U.S.C. § 1144(a)).

Key Sixth Circuit precedents include:

• Gardner v. Heartland Industrial Partners, LP, 715 F.3d 609 (6th Cir. 2013) — Describes ERISA’s “extraordinary pre-emptive power” and clarifies that a duty is “independent” under Davila only if it is not derived from, or conditioned upon, the plan terms and can be determined without interpreting the plan. Gardner supplies the core test for Davila’s second prong used here.
• Hogan v. Jacobson, 823 F.3d 872 (6th Cir. 2016) — Explains that “complete preemption” is a “misleadingly named doctrine” better understood as jurisdictional. Hogan also notes that when claims are completely preempted, courts typically allow repleading as ERISA causes of action rather than dismiss outright.
• K.B. ex rel. Qassis v. Methodist Healthcare – Memphis Hospitals, 929 F.3d 795 (6th Cir. 2019) — Emphasizes that courts must look to the “essence” of the claim rather than its label when deciding whether a suit is “in essence” one for ERISA benefits. Patterson uses this to justify looking past state tort labels.
• Smith v. Provident Bank, 170 F.3d 609 (6th Cir. 1999) — Extends complete preemption to ERISA § 502(a)(2), recognizing that § 502(a) as a whole has preemptive force, a point the panel analogizes to § 502(a)(3).

On procedural standards, the court relies on:

• City of Cleveland v. Ameriquest Mortgage Securities, Inc., 615 F.3d 496 (6th Cir. 2010) — De novo review of remand denials.
• Operating Engineers’ Local 324 Fringe Benefit Funds v. Rieth-Riley Construction Co., 43 F.4th 617 (6th Cir. 2022) — De novo review of dismissals involving ERISA preemption.
• Forman v. TriHealth, Inc., 40 F.4th 443 (6th Cir. 2022), applying Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) — For the plausibility standard on motions to dismiss.

3. Other Circuits’ Decisions on Reimbursement and Complete Preemption

On the central issue—whether state-law challenges to ERISA plan reimbursement rights are “benefit” claims under § 502(a)(1)(B)—the court canvasses several circuit decisions:

• Third Circuit:
  • Wirth v. Aetna U.S. Healthcare, 469 F.3d 305 (3d Cir. 2006) — A participant paid his insurer out of a tort settlement after the insurer asserted reimbursement rights under an ERISA plan. When he later sued in state court for unjust enrichment and related theories, the Third Circuit held his claims were completely preempted because they were, at bottom, attempts to “recover benefits due” or enforce rights under the plan. This case is the Sixth Circuit’s main analog for Patterson.
  • Levine v. United Healthcare Corp., 402 F.3d 156 (3d Cir. 2005) — Emphasizes that preemption should not turn on the “fortuity of when a plan term was misapplied to diminish the benefit.” The Sixth Circuit quotes this to reject the argument that preemption disappears once benefits are initially paid but later clawed back.
• Fifth Circuit:
  • Arana v. Ochsner Health Plan, 338 F.3d 433 (5th Cir. 2003) (en banc) — Holds that a suit contesting a plan’s assertion of reimbursement rights is effectively a claim to recover benefits under § 502(a)(1)(B) because the participant has not received benefits “free and clear” of the plan’s claim.
• Fourth Circuit:
  • Singh v. Prudential Health Care Plan, Inc., 335 F.3d 278 (4th Cir. 2003) — Similarly treats reimbursement disputes as benefit claims, warning against allowing jurisdiction to turn solely on timing.
• Ninth Circuit:
  • Rudel v. Hawaii Management Alliance Ass’n, 937 F.3d 1262 (9th Cir. 2019) — Concludes that a participant has not fully recovered benefits if they remain “under a cloud” due to the plan’s asserted reimbursement rights, aligning with the Third, Fourth, and Fifth Circuits.
• Second Circuit:
  • Wurtz v. Rawlings Co., 761 F.3d 232 (2d Cir. 2014) — The outlier case invoked by Patterson. There, participants challenged their plan’s reimbursement rights under a state insurance statute and expressly did not claim a right to keep their settlements under the terms of their plans. The Second Circuit held that Davila’s first prong was not met because the claims were based on a state law, not on plan terms. The Sixth Circuit explicitly declines to follow this reasoning in Patterson.

The Sixth Circuit sides with Wirth, Arana, Singh, Levine, and Rudel, and distinguishes or critiques Wurtz, emphasizing that Patterson’s own complaint grounds his rights in the “terms and conditions” of the ERISA plan, not in some freestanding state statute.

4. Other Precedent on Fraud Claims, Independent Duties, and Duplicative Suits

The court also draws on:

• Briscoe v. Fine, 444 F.3d 478 (6th Cir. 2008), and Arora v. Henry Ford Health System, 2018 WL 3760888 (6th Cir. July 9, 2018) (unpublished) — Both involve fraud or misrepresentation claims that were found completely preempted, illustrating that common-law fraud is not categorically beyond ERISA’s preemptive scope when plan terms are central.
• Matthews v. Centrus Energy Corp., 15 F.4th 714 (6th Cir. 2021) — Holds that a party who has “disclaimed reliance” on a theory cannot later revive it, supporting the conclusion that Patterson, having disavowed a § 502(a)(1)(B) claim, cannot now recast his state claims as such.
• Waad v. Farmers Insurance Exchange, 762 F. App’x 256 (6th Cir. 2019), and Smith v. SEC, 129 F.3d 356 (6th Cir. 1997) — Recognize district courts’ discretion to dismiss duplicative lawsuits.
• Church Joint Venture, L.P. v. Blasingame, 817 F. App’x 142 (6th Cir. 2020), and Ellis v. Gallatin Steel Co., 390 F.3d 461 (6th Cir. 2004) — Discuss the doctrine of “claim-splitting” and affirm the power to dismiss a later-filed case arising from the same set of facts.
• State-law authorities such as Zipkin v. FirstMerit Bank N.A., 176 N.E.3d 86 (Ohio Ct. App. 2021) (elements of conversion), and Addison Holdings, LLC v. Fox, Byrd & Co., 203 N.E.3d 1259 (Ohio Ct. App. 2022) (civil conspiracy requires an underlying tort), are used to show how Patterson’s tort theories necessarily hinge on whether the plan actually authorized reimbursement.

B. The Court’s Legal Reasoning

1. Framing Complete Preemption: Beyond the Label “Preemption”

The court begins by clarifying the nature of “complete preemption” under ERISA:

• It is not a typical affirmative defense that merely bars application of state law.
• Instead, it is a jurisdictional doctrine under which certain state-law claims are recharacterized as arising under federal law (ERISA § 502(a)) for purposes of subject-matter jurisdiction.
• Because of this, ERISA forms an exception to the well-pleaded complaint rule: even if the plaintiff pleads only state-law causes of action, if those claims fall within § 502(a), federal-question jurisdiction exists.

The court underscores the distinction with “express preemption” under ERISA’s § 514 (29 U.S.C. § 1144(a)), which preempts state laws that “relate to” ERISA plans but does not itself create removal jurisdiction. In this case, both parties and the courts focus exclusively on complete preemption.

2. Davila Prong One: Are Patterson’s Claims, in Essence, ERISA Benefit Claims?

Under Davila’s first prong, the question is whether Patterson:

and could at some point have brought his claim under § 502(a).

The Sixth Circuit’s analysis proceeds in several steps:

1. Looking Past Labels to Substance. Drawing on K.B. ex rel. Qassis, the court emphasizes that it must look to the “essence” of the claim, not the state-law labels (fraud, conversion, unjust enrichment). This ensures that a plaintiff cannot evade ERISA by clever pleading.
2. Reimbursement as Diminution of Benefits. The court adopts the reasoning of Wirth, Arana, Singh, and Rudel:
   • Even if the plan paid all medical bills at the outset, a later demand for reimbursement from the participant’s tort recovery effectively diminishes the net benefits.
   • The participant has not fully “recovered benefits due” under § 502(a)(1)(B) until he possesses those benefits “free and clear” of the plan’s asserted reimbursement claim.
   • As the Third Circuit put it in Wirth, the fact that the literal dollars used to reimburse the plan differ from those used to pay medical bills is irrelevant; what matters is the overall diminution of the participant’s benefit package.
3. Rejecting the “Benefits Were Already Paid” Argument. Patterson argued that, because his medical bills had already been paid, he was not seeking to recover “benefits due” under the plan but rather to recover separate damages in tort. The court finds this unpersuasive:
   • Allowing jurisdiction to hinge on whether the alleged misapplication of plan terms occurred before or after the plan pays would be arbitrary and would defeat the uniformity ERISA seeks to ensure.
   • Following Levine, the “fortuity of when a plan term was misapplied” cannot control the existence of complete preemption.
4. Patterson Actually Brought a § 502(a)(1)(B) Claim Before. The court notes an important factual point: in his first federal ERISA action, Patterson did assert a § 502(a)(1)(B) claim based on the same core grievance—that defendants used a misleading SPD and misrepresentations to claw back $25,000. This historical fact underscores that he could have brought his present claims under § 502(a)(1)(B); indeed, he already did so once.
5. Distinguishing Wurtz v. Rawlings. The Second Circuit in Wurtz declined to find complete preemption where participants sued based on a state insurance statute and did not claim any right under their plan terms to retain their settlements. The Sixth Circuit distinguishes Wurtz on two grounds:
   • Wurtz focused too heavily on the nominal source of the legal duty (state statute) rather than looking at the underlying nature of the relief, contrary to the “essence” approach.
   • Unlike the Wurtz plaintiffs, Patterson expressly bases his claim to retain the $25,000 on the terms of his ERISA plan (specifically, the absence of any plan-based reimbursement obligation in the controlling plan document).

Based on this reasoning, the court holds that Patterson’s claims satisfy Davila’s first prong via § 502(a)(1)(B). Although it notes that § 502(a)(3) also likely has complete preemptive force, it finds it unnecessary to reach that question given the clear fit with § 502(a)(1)(B).

3. Davila Prong Two: Are the Alleged Duties Independent of ERISA and the Plan?

The second Davila prong asks whether the plaintiff alleges the violation of a legal duty “independent” of ERISA or the plan terms. Under Gardner:

• A duty is “independent” only if it does not derive from or depend on the plan and
• No one needs to interpret the plan to determine whether that duty exists or has been breached.

Applying that framework, the court analyzes each of Patterson’s state-law theories:

1. Fraudulent and Negligent Misrepresentation.
   • Patterson alleges that defendants falsely represented that he had agreed to reimbursement rights in his plan and that they either knew this was false or negligently failed to review the plan document.
   • That allegation presupposes a particular set of rights and obligations under the plan (namely, that no reimbursement provision exists in the controlling plan document).
   • The duty at issue is not a generalized duty “not to defraud” in the abstract; it is a specific duty not to misrepresent the parties’ obligations under the ERISA plan. Without the plan and its terms, there is no content to this alleged misrepresentation.
   • Accordingly, the fraud-based duties are only “nominally” independent and fail Davila’s second prong.
2. Conversion.
   • Under Ohio law, conversion requires wrongful exercise of dominion over property in denial of another’s rights.
   • Patterson claims a right to possess the $25,000 he paid; defendants cannot have wrongfully interfered with this right if the plan did impose a reimbursement obligation.
   • Thus, whether defendants’ possession was “wrongful” turns entirely on whether the plan authorized reimbursement—a question of ERISA plan interpretation.
3. Unjust Enrichment.
   • Patterson dropped this claim in the district court, but the panel notes in passing that unjust enrichment would likewise depend on whether defendants’ acquisition of the money was “unjust” in light of the plan’s terms.
   • If the plan granted a reimbursement right, retaining the money would not be unjust; if not, it might be. Again, that is a question of plan interpretation.
4. Civil Conspiracy.
   • Under Ohio law, civil conspiracy is not a stand-alone tort; it requires an underlying actionable tort (e.g., fraud or conversion).
   • Patterson concedes that the conspiracy claim stands or falls with his other tort claims, all of which are intertwined with plan interpretation.

Patterson offered several counterarguments:

• No Need to Interpret the Plan? He argued that defendants lied about the existence of the plan document, not its meaning, and thus no plan interpretation is needed. The court rejects this as inconsistent with the litigation history. Once the plan document surfaced, the Ohio courts were required to interpret its relationship to the SPD and to decide whether it authorized reimbursement—precisely the kind of plan interpretation Davila focuses on.
• Prior State Judgment as a Substitute for Interpretation? Patterson asserted that because a state court has already held that the plan did not allow reimbursement, a federal court need not revisit plan interpretation. The Sixth Circuit responds that the Davila inquiry is not about whether the plan’s meaning is contested, but whether any court had to interpret the plan to determine the duty. The fact that an Ohio court did that work merely confirms that the duty is not independent.
• Fraud as Traditional State Regulation. Invoking Travelers, Patterson argued that fraud prevention is a traditional area of state regulation that Congress did not intend ERISA to displace. The Sixth Circuit notes that any presumption against preemption has not been applied in the complete-preemption context and points to prior cases (Briscoe, Arora) where fraud-based claims were found completely preempted when anchored in plan terms.

In short, the court concludes that all of Patterson’s state-law causes of action fail Davila’s second prong because they are inextricably tied to, and require interpretation of, the ERISA plan’s reimbursement provisions (or lack thereof).

4. Remedy: Recharacterize vs. Dismiss, and the Problem of Duplicative Litigation

After finding complete preemption, a federal court typically does not dismiss the claim as “preempted”; instead, it:

• Treats the complaint as stating a federal cause of action under ERISA § 502(a), and
• Allows the plaintiff to amend the complaint or proceed under ERISA theories.

In Patterson, however, the district court instead dismissed the entire action as duplicative. The Sixth Circuit affirms this choice, reasoning:

1. Disavowed § 502(a)(1)(B) Claim Cannot Be Revived.
   • In the first federal suit, Patterson had pled a § 502(a)(1)(B) claim but then affirmatively disavowed that theory on appeal.
   • Under Matthews v. Centrus Energy, a litigant who “disclaims reliance” on a claim cannot resurrect it in later proceedings. Thus, Patterson cannot now reassert § 502(a)(1)(B) as his federal theory.
2. Existing § 502(a)(3) Claim Makes a Second Suit Duplicative.
   • Patterson’s first federal suit, now on remand, already includes a § 502(a)(3) claim seeking equitable relief for the same $25,000 reimbursement based on the same underlying plan misrepresentations.
   • Recasting the new state-law claims as § 502(a)(3) claims would simply duplicate the pending lawsuit.
   • Under Waad, Smith, Church Joint Venture, and Ellis, district courts have ample authority to dismiss later-filed suits that involve the same parties, facts, and remedies (claim-splitting).
3. Discretionary Dismissal Is Proper Case Management.
   • Allowing parallel ERISA actions to proceed in the same court about the same $25,000 would unreasonably burden the court and risk inconsistent results.
   • Patterson does not meaningfully challenge the dismissal as an abuse of discretion; his objections relate primarily to the preemption analysis and remand denial.

Accordingly, the court holds that, given Patterson’s litigation choices, the district court was entitled to dismiss the removed action in its entirety rather than recharacterize or consolidate it.

C. Impact and Implications

1. For ERISA Beneficiaries and Plaintiffs’ Counsel

• Limited Scope for State-Law Workarounds. Participants cannot avoid ERISA’s remedial framework by re-labeling disputes over plan reimbursement or benefit entitlement as fraud, conversion, unjust enrichment, or conspiracy claims. If those claims depend on plan terms, they are likely to be completely preempted.
• Reimbursement Clawbacks = “Benefits Due.” The decision confirms that when a participant says, “I never should have had to pay that money back; the plan did not give you that right,” the claim is functionally to “recover benefits due” under § 502(a)(1)(B)—even if the original medical bills were fully paid at the outset.
• Strategic Consequences of Disavowing ERISA Theories. Patterson illustrates the peril of disavowing certain ERISA causes of action to pursue narrower theories or to avoid perceived obstacles (e.g., limitations on damages or jury trial). Once disclaimed, those theories may be foreclosed in later litigation.
• Risk of Parallel and Duplicative Actions. Plaintiffs who file state-law actions while ERISA suits are pending risk removal and dismissal for claim-splitting, particularly if both suits target the same relief for the same underlying conduct.

2. For Plan Sponsors, Insurers, and Administrators

• Robust Removal Tool. Patterson strengthens the ability of ERISA defendants to remove state-law suits involving reimbursement, subrogation, or coordination-of-benefits disputes to federal court on the basis of complete preemption.
• Uniform Federal Forum for Reimbursement Litigation. By aligning with other circuits that treat reimbursement clawbacks as § 502(a)(1)(B) issues, the Sixth Circuit contributes to a more uniform federal regime where plan terms—not divergent state tort principles—govern such disputes.
• Importance of Accurate SPDs and Prompt Disclosure of Plan Documents. Although the opinion is favorable to defendants on preemption and jurisdiction, it arises from conduct—non-disclosure and apparent misstatements about the existence and content of the plan document—that exposed the plan to significant ERISA liability in the first suit. Administrators should see this as a cautionary tale on ERISA’s disclosure obligations and fiduciary duties.

3. For Courts and ERISA Doctrine

• Clarification of Davila’s “Independent Duty” Prong. Patterson reinforces that a duty is not “independent” merely because it arises under a general state-law rubric (e.g., “fraud,” “conversion”) or from a separate source. The analysis turns on whether the alleged duty can be defined and enforced without referring to plan terms.
• Positioning Within the Circuit Split on Wurtz. While not formally creating a split (because the facts differ), the decision signals skepticism toward Wurtz’s emphasis on the nominal statutory source of the duty rather than the functional nature of the claim. In practice, Patterson makes it harder, within the Sixth Circuit, to keep state-law reimbursement challenges in state court.
• Implicit Endorsement of § 502(a)(3)’s Complete Preemptive Force. Although the panel did not need to decide the question, its discussion—citing Taylor and Davila’s references to the preemptive “force” of § 502(a) as a whole, and noting that other circuits treat § 502(a)(3) as completely preemptive—points toward a broad view of ERISA’s remedial preemption across the subsections of § 502(a).
• Docket Management and Claim-Splitting. The opinion confirms district courts’ discretion to dismiss removed actions as duplicative rather than automatically recharacterize and consolidate them, especially where plaintiffs are attempting to circumvent earlier strategic choices about their ERISA remedies.

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V. Complex Concepts Simplified

1. ERISA and Employer Health Plans

The Employee Retirement Income Security Act of 1974 (ERISA) is a federal statute that sets rules for most employer-sponsored benefit plans, including health insurance. It governs:

• What documents must be provided to participants (including SPDs and plan documents),
• How plans must be administered, and
• How participants can sue to enforce their rights (under § 502(a), 29 U.S.C. § 1132(a)).

2. Plan Document vs. Summary Plan Description (SPD)

• Plan document: The formal legal instrument that sets the actual terms of the benefit plan (e.g., who is covered, what benefits they receive, what exclusions and reimbursement rights exist).
• SPD: A summary meant to explain the plan in understandable language. Under ERISA, if there is a conflict, the governing plan document usually controls, especially where, as in Patterson, the plan document says it is controlling.

3. Reimbursement and Subrogation

In many health plans, when a participant is injured by a third party and the plan pays medical costs, the plan may:

• Seek reimbursement from the participant’s tort recovery (the participant repays the plan), or
• Exercise subrogation rights to pursue the tortfeasor directly for the amounts paid.

In Patterson, the dispute centers on whether the plan actually had any contractual right to reimbursement under the controlling plan document.

4. Complete Preemption vs. Express Preemption

• Express (or “conflict”) preemption: Under ERISA § 514 (29 U.S.C. § 1144(a)), state laws that “relate to” an ERISA plan are displaced. This is a defense to a state-law claim and does not by itself confer federal jurisdiction for removal.
• Complete preemption: Under ERISA § 502(a), some state-law claims are treated as if they were federal ERISA claims from the outset. This is a jurisdictional doctrine that allows removal to federal court even when the complaint cites only state law, provided the claim fits within § 502(a).

5. The Well-Pleaded Complaint Rule and Its ERISA Exception

• Well-pleaded complaint rule: Normally, federal jurisdiction depends on what is pled in the complaint; federal defenses (like preemption) do not create jurisdiction.
• ERISA exception: If a plaintiff’s state-law claim is really a claim for benefits or to enforce plan rights under § 502(a), federal courts treat it as a federal ERISA claim and assert jurisdiction regardless of how the plaintiff labels it.

6. ERISA § 502(a)(1)(B) vs. § 502(a)(3)

• § 502(a)(1)(B) (29 U.S.C. § 1132(a)(1)(B)) — Allows a participant to:
  • Recover benefits due under the plan,
  • Enforce rights under the plan, or
  • Clarify rights to future benefits.
  Disputes over entitlement to payment or over plan-imposed reimbursement are classic § 502(a)(1)(B) claims.
• § 502(a)(3) (29 U.S.C. § 1132(a)(3)) — Authorizes suits by participants or beneficiaries:
  • To enjoin violations of ERISA or the plan, or
  • To obtain “other appropriate equitable relief” for such violations (e.g., restitution, disgorgement, reformation, surcharge for fiduciary breach).
  It is often used where legal remedies (like simple payment of benefits) are insufficient or unavailable.

7. “Independent Legal Duty” Under Davila

Under Davila, a duty is “independent” of ERISA and the plan only if:

• It exists regardless of the plan’s terms, and
• It can be enforced without interpreting or applying the plan.

For example, a state-law duty not to negligently injure someone in a car accident is independent of any ERISA plan. By contrast, a duty not to misrepresent plan benefits or reimbursement rights is intertwined with the plan and not independent.

8. Claim-Splitting and Duplicative Litigation

“Claim-splitting” occurs when a plaintiff files two different lawsuits based on the same underlying events and seeking essentially the same relief. Courts generally:

• Require plaintiffs to bring all related claims in one action, and
• May dismiss later-filed suits as duplicative to protect judicial economy and avoid inconsistent rulings.

In Patterson, this doctrine supports the dismissal of his second (removed) action, which overlaps with his first federal ERISA suit.

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VI. Conclusion: Significance of Patterson in the Broader Legal Landscape

The Sixth Circuit’s decision in Patterson v. UnitedHealth Group, Inc. cements several important propositions in ERISA litigation:

• Reimbursement clawbacks are ERISA benefit disputes. When a participant claims that the plan wrongfully demanded reimbursement for medical expenses—especially by invoking misleading summaries or misrepresentations about plan documents—the dispute is, at its core, about “benefits due” under § 502(a)(1)(B). This is true even if the benefits were initially paid and only later “diminished” through reimbursement.
• State-law fraud and restitution theories are not independent when they hinge on plan terms. Claims for fraud, negligent misrepresentation, conversion, unjust enrichment, and conspiracy are completely preempted where their success turns on whether the ERISA plan did or did not authorize the challenged payment.
• Complete preemption serves ERISA’s goal of uniformity. By bringing reimbursement and subrogation disputes under the umbrella of federal ERISA litigation, the court furthers Congress’s intent that plan administration not be fractured by divergent state-law standards and remedies.
• Litigation strategy under ERISA has lasting consequences. Plaintiffs who disavow specific ERISA remedies (like § 502(a)(1)(B)) or attempt to pursue parallel state suits risk losing their ability to reframe claims later, and may see later-filed actions dismissed as duplicative.

In the end, Patterson reinforces ERISA’s central promise: disputes about rights and obligations under employer-sponsored benefit plans—including disputes over whether participants must reimburse plans from tort recoveries—belong in a uniform federal forum and are governed by ERISA’s carefully constructed remedial scheme, not by a patchwork of state tort rules. For practitioners in the Sixth Circuit and beyond, the case is a clear signal that state-law attacks on plan reimbursement arrangements, when grounded in plan terms, will be drawn inexorably into ERISA’s preemptive orbit.