Munoz v. Reliance Standard Life Insurance Company
- Maxine Chesney
- 3:22-cv-09160
- U.S. District Court · Northern District of California
- 2
In Munoz v. Reliance Standard Life Insurance Company, Judge Chesney dismissed Munoz’s state-law claims and struck related damages requests as preempted by ERISA.
Jo Munoz’s state-law claims for fraudulent misrepresentation and breach of the implied covenant of good faith and fair dealing, and her related requests for general, punitive, and exemplary damages, were dismissed or struck. Reliance Standard Life Insurance Company obtained that ruling.
What happened
In Munoz v. Reliance Standard Life Insurance Company, Jo Munoz alleged that Reliance improperly denied her disability-benefits claim. She sought disability benefits and other relief under the Employee Retirement Income Security Act (ERISA), as well as damages under state law.
The court held that Munoz’s state-law claims for fraudulent misrepresentation and breach of the implied covenant of good faith and fair dealing were displaced by ERISA because they concerned the handling of her benefits claim. The court also struck her requests for general, punitive, and exemplary damages, which it said related only to those state-law claims.
Judge Maxine M. Chesney granted Reliance’s motion to dismiss and strike, dismissed the Third and Fourth Claims for Relief, vacated the hearing, and scheduled a case-management conference for May 5, 2023.
The detailed version
- Munoz v. Reliance Standard Life Insurance Company · No. 3:22-cv-09160
- Maxine Chesney
- Apr. 3, 2023
Background
Jo Munoz alleged that Reliance Standard Life Insurance Company improperly denied her claim for disability benefits. Her complaint sought disability benefits and other relief under the Employee Retirement Income Security Act (ERISA), along with damages under state law.
Reliance moved to dismiss Munoz’s Third Claim for Relief, which alleged fraudulent misrepresentations made in connection with handling her benefits claim. It also moved to dismiss the Fourth Claim for Relief, which alleged that Reliance breached the implied covenant of good faith and fair dealing through unreasonable and improper actions during that process. Reliance further moved to strike requests for general, punitive, and exemplary damages.
Court’s analysis
The court concluded that Munoz’s state-law claims were preempted by ERISA. ERISA preemption means that federal law displaces certain state-law claims that relate to an ERISA plan. Relying on the reasons presented by Reliance and cited authority, the court determined that claims based on the processing of an ERISA benefits claim—including fraud and alleged bad-faith or unreasonable claim handling—were preempted.
Ruling and case schedule
The court granted Reliance’s motion, dismissed the Third and Fourth Claims for Relief, and struck the complaint’s requests for general, punitive, and exemplary damages because those requests pertained solely to Munoz’s state-law claims. The court vacated the hearing that had been scheduled for April 7, 2023, and set a case-management conference for May 5, 2023, at 10:30 a.m. A joint case-management statement was due April 28, 2023. Judge Maxine M. Chesney signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.