Sixth Circuit Reaffirms ERISA Preempts State Law Claims Arising from Benefits Verification Calls

On August 19, 2026, the Sixth Circuit held in Laurel Hill Management Services, Inc., v. La-Z-Boy, Inc., No. 25-1727 (6th Cir. Aug. 19, 2026) (“Laurel Hill”) that the Employee Retirement Income Security Act of 1974 (“ERISA”) preempts state law negligent misrepresentation and promissory estoppel claims brought by out-of-network providers “when those claims arise out of an ERISA-plan administrator’s oral assurances [during a benefits verification call] about the terms of coverage or reimbursement”... By: Mayer Brown