Garan v. New York-Presbyterian Hospital

Background

Jozef Garan filed this action against New York-Presbyterian Hospital in New York state court. He alleges that he was denied benefits owed under the hospital’s employee pension plan. The hospital removed the case to the U.S. District Court for the Southern District of New York, arguing that the plan is governed by the Employee Retirement Income Security Act of 1974 (ERISA), a federal law governing employee benefit plans.

Garan, who was representing himself, moved to remand the case, meaning he asked the federal court to return it to state court.

Court’s analysis

The court held that, based on the allegations in Garan’s complaint, the hospital’s pension plan is an ERISA pension plan because it is maintained by an employer to provide retirement income to employees. The court concluded that Garan’s lawsuit therefore falls under ERISA’s provision for a plan beneficiary seeking to recover benefits due under the plan.

ERISA gives state courts and federal district courts concurrent jurisdiction over this type of benefits lawsuit. In other words, both state and federal courts may hear it. The court also found that the hospital’s removal complied with the applicable requirements and that Garan had not identified any removal error.

Ruling

Judge Arun Subramanian denied Garan’s motion for remand. The clerk was directed to terminate the motion at Dkt. 9. The order addressed the proper court for the case and did not decide whether Garan is entitled to the disputed pension benefits.