Prince v. Sears Holdings Corp., No. 16-1075 (4th Cir. 2017)Annotate this Case
Plaintiff filed suit against his employer, Sears, alleging misrepresentation, constructive fraud, and infliction of emotional distress. Specifically, plaintiff alleged that Sears improperly administered life insurance benefits. The district court dismissed the complaint. Sonoco Prods. Co. v. Physicians Health Plan, Inc. held that section 502(a) of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a), preempts a state law claim when: the plaintiff has standing, the claim must fail under the scope of an ERISA provision that can enforce via section 502(a), and the claim must not be capable of resolution without an interpretation of the contract governed by federal law. Because plaintiff's claims meets all three prongs of the Sonoco test, the court concluded that ERISA completely preempts his claims. Accordingly, the court affirmed the judgment.