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Click here for the full text of this decision FACTS:Mattie Stiles was injured working at Memorial Hermann Healthcare System. Stiles asserts that Memorial agreed to pay her health care expenses related to the incident in consideration of Stiles releasing Memorial from liability for any negligence on its part. Stiles attached an unsigned Release of Claims and Covenant not to Sue to her second amended petition evidencing such an agreement. The release referenced Memorial’s Occupational Health Plan (plan) and stated that notwithstanding Stiles’s release of her claims against Memorial, Stiles retained her rights to benefits under the Plan. Stiles alleges that Memorial refused to pay her medical bills pursuant to the release. Memorial answered Stiles’ suit with a general denial and argued, among other things, that the trial court lacked subject matter jurisdiction to hear Stiles’ claims. Memorial then filed a notice of removal asserting that Stiles’ petition stated an action to recover benefits under the plan which qualified under the Employee Retirement Income Security Act of 1974, thereby triggering complete pre-emption under ERISA’s civil enforcement provisions. The trial court ruled in favor of removal, and the case was removed to the U.S. District Court of the Southern District of Texas. In Stiles’ subsequent motion to remand, she contended that it was Memorial’s breach and fraud related to the release agreement, distinct from any rights that she held under the plan, that formed the basis of her suit. The U.S. District Court remanded the case back to the trial court for lack of federal jurisdiction stating, “substantial doubt remains as to whether [Stiles'] claim does in fact fall within the preemptive scope of ERISA.” Upon remand, Memorial moved to dismiss the suit, again arguing a lack of subject matter jurisdiction based on ERISA preemption. The trial court granted the motion to dismiss, concluding that Stiles’ state law claims for breach of contract and fraud were “addressed by” and “related to” the plan, that ERISA “completely pre-empted” Stiles’ state law claims, and that it had no subject matter jurisdiction over the claims. HOLDING:Reversed and remanded. The plan contemplates the type of release agreement at issue in this case. Article VI of the plan, contained in the record, states: “As a condition of the Plan, . . . the Plan Administrator reserves the right to require any Employee who incurs a Bodily Injury . . . to execute and deliver to the Plan Administrator, on a form provided by the Plan Administrator, a full release of liability and covenant not to sue (except with respect to Benefits claims under the Plan), before Benefits are awarded under the Plan or at any other time in consideration for the award of any Benefits.” The release reflects that Stiles bargained for a distinct and independent promise from Memorial to pay her medical bills in consideration of her release of any claims against Memorial arising from the incident. The court concludes that the underlying conduct complained about in this case, breach of contract and fraud, can be divorced from its connection to the employee benefit plan. Moreover, the court notes that Stiles’ state law claims, as pleaded, do not address areas of exclusive federal concern as she is not seeking the right to receive benefits under the terms of an ERISA plan, nor do her claims directly affect the relationship among the traditional ERISA entities. The court holds that Stiles’ claims based on the breach of the release agreement do not relate to Memorial’s ERISA-qualifying plan so as to pre-empt state court jurisdiction over her claims. OPINION:Terry Jennings, J.; Radack, C.J., Jennings and Alcala, J.J.

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