## Facts

- Miller was an employee and plan participant in ERISA-governed employee benefit plan(s) sponsored by U.S. Foodservice, Inc.
- Miller alleged the defendants failed to provide, continue, properly calculate, or clarify benefits allegedly owed under the plan(s).
- The complaint asserted ERISA-based claims under ERISA’s civil enforcement provisions and also asserted overlapping state-law theories (e.g., contract- or tort-style benefit claims).
- Defendants moved to dismiss (or, alternatively, for summary judgment), arguing ERISA supplied the exclusive remedy and preempted the state-law claims, and that some ERISA theories were legally improper or duplicative.
- Miller argued his claims were adequately pleaded and that certain non-ERISA theories were independent of ERISA or not preempted.

## Issues

1. Whether Miller’s state-law claims seeking benefits or benefit-related relief were preempted and displaced by ERISA.
2. Whether Miller’s benefits-related dispute had to proceed under ERISA § 502(a)(1)(B) as the exclusive cause of action to recover benefits, enforce plan rights, or clarify future benefits.
3. Whether Miller could pursue equitable relief under ERISA § 502(a)(3) when § 502(a)(1)(B) provided an adequate remedy.
4. Whether the complaint stated a viable ERISA claim sufficient to survive dismissal as to the core benefits dispute.

## Decision

- The court granted the defendants’ motion to dismiss (or summary judgment) as to state-law claims that sought to recover, enforce, or clarify rights to benefits under the ERISA plan(s).
- The court held that the dispute, as a participant’s suit to recover or clarify plan benefits, fell within ERISA § 502(a)(1)(B), which supplies the exclusive federal vehicle for such claims.
- The court dismissed or narrowed claims framed under ERISA § 502(a)(3) to the extent they sought relief duplicative of the § 502(a)(1)(B) benefits remedy.
- The court allowed the case to proceed on a properly pleaded ERISA § 502(a)(1)(B) claim alleging wrongful denial or miscalculation of benefits due under the plan terms.

## Legal Principles

- ERISA preempts state-law causes of action that “relate to” an employee benefit plan where the claims, in substance, seek plan benefits or enforcement/clarification of plan-created rights.
- ERISA § 502(a)(1)(B) is the exclusive cause of action for a participant seeking to recover benefits due under the plan, enforce rights under the plan, or clarify rights to future benefits.
- ERISA § 502(a)(3) authorizes equitable relief only when ERISA does not otherwise provide an adequate remedy; it cannot be used to repackage a benefits claim or obtain duplicative relief where § 502(a)(1)(B) applies.
- Channeling benefit disputes into § 502(a)(1)(B) serves ERISA’s goal of uniform federal regulation of employee benefit plans and prevents end-runs through state-law remedies.

## Conclusion

The court enforced ERISA’s preemptive and remedial scheme by dismissing state-law and duplicative equitable theories and permitting only a benefits-based claim under ERISA § 502(a)(1)(B) to go forward to resolve the alleged denial or miscalculation of plan benefits.


Miller v. U.S. Foodservice, Inc., 361 F. Supp. 2d 470 (D. Md. 2005)