Although the ERISA law generally preempts state law causes of action that relate to claims for employee benefits, a recent federal court ruling from California Dale v. Reed Group, Ltd., 2015 WL 6954915 (N.D. Cal. November 10, 2015), permitted an exception to that general rule. Ed Dale, an employee of Intel Corporation who became disabled, was refused long-term disability benefits. In challenging the benefit denial, he added a claim for intentional infliction of emotional distress (IIED), which Intel and its benefit administrators tried to have dismissed on ERISA preemption grounds. He maintained that in the course of his claim, he was accused of lying or exaggerating his claims, urged to take experimental medication and forced to undergo examinations that caused pain, emotional distress and anxiety.
The court sustained the IIED claim because it alleged "harassing and oppressive conduct independent of the duties of administering an ERISA plan" and also involved a legal duty independent of ERISA. The court determined that Dale's allegations were "based on events that involved harassing and oppressive conduct." And most significantly, the court explained that "even without the denial of benefits our plaintiff would still have a claim for intentional infliction of emotional distress." The last point is the key. Because Dale could potentially win a claim for infliction of emotional distress regardless of the outcome of his claim for benefits, his claim was sustained.