The Supreme Court of the United States issued decisions in two cases on March 1, 2016:
Gobeille v. Liberty Mut. Ins. Co., No. 14-181: Respondent Liberty Mutual Insurance Company, which has an “employee welfare benefit plan” under the Employee Retirement Income Security Act of 1974 (ERISA), brought a pre-emption challenge in federal court after its third-party administrator was ordered by the State of Vermont to transmit files on member eligibility, medical claims, and pharmacy claims for Vermont members pursuant to Vermont’s reporting statute, which established an all-inclusive health care database. The District Court granted summary judgment to Vermont, but the Second Circuit reversed on pre-emption grounds. Today, the Court affirmed, holding that ERISA’s express pre-emption of “any and all State laws insofar as they may now or hereafter relate to any employee benefit plan,” 29 U.S.C. §1144(a), requires invalidation of the Vermont reporting statute as applied to ERISA plans.
The Court's decision is available here.
Lockhart v. United States, No. 14-8358: If a defendant is convicted of possessing child pornography under 18 U.S.C. §2252(a)(4), they are then subject to a ten-year mandatory minimum sentence under §2252(b)(2) if they have “a prior conviction . . . under the laws of any State relating to aggravated sexual abuse, sexual abuse, or abusive sexual conduct involving a minor or ward.” Petitioner Avondale Lockhart pleaded guilty to possessing child pornography and was sentenced under the mandatory minimum sentence enhancement due to a prior state-court conviction for first-degree sexual abuse involving his adult girlfriend. Both the District Court and the Second Circuit rejected Lockhart’s argument that the limiting phrase “involving a minor or ward” applied to all three state crimes, thus rendering the enhancement inapplicable to him. The Court today affirmed, holding that the phrase “involving a minor or ward” in §2252(b)(2) modifies only “abusive sexual conduct.”
The Court's decision is available here.
