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Aetna Health Inc. v. Davila
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Aetna Health Inc. v. Davila : ウィキペディア英語版
Aetna Health Inc. v. Davila

''Aetna Health Inc. v. Davila'', , was a United States Supreme Court case in which the Court limited the scope of the Texas Healthcare Liability Act (THCLA). The effective result of this decision was that the THCLA, which held Case Management and Utilization Review decisions by Managed Care entities like CIGNA and Aetna to a legal duty of care according to the laws of The State of Texas could not be enforced in the case of Health Benefit plans provided through private employers, because the Texas statute allowed compensatory or punitive damages to redress losses or deter future transgressions, which were not available under ERISA § 1132. The ruling still allows the State of Texas to enforce the THCLA in the case of Government-sponsored (Medicare, Medicaid, Federal, State, Municipal Employee, etc., Church-sponsored, or Individual Health Plan Policies (High-deductible individual policies, self-pay, any insurance not subsidised by a Private Employer), which are saved from preemption by ERISA. The history that allows these Private and Self-Pay Insurance to be saved dates to the "Interstate Commerce" power that was given the federal Government by the Supreme Court. ERISA, enacted in 1974, relied on the "Interstate Commerce" rule to allow federal jurisdiction over private employers, based on the need of private employers to follow a single set of paperwork and rules for pensions and other employee benefit plans where employers had employees in multiple states. Except for private employer plans, insurance can be regulated by the individual states, and Managed Care entities making medical decisions can be held accountable for those decisions if negligence is involved, as allowed by the Texas Healthcare Liability Act.
== Opinion of the Court ==
The Court ruled that Mr. Davila's and Ms. Calad's (the Respondents') state of Texas Causes of Action, both involving Utilization Review decisions by Managed Care entities (in this case CIGNA and Aetna) that were alleged to adversely affect patient care, where in both cases Utilization review decisions contradicted the advice of the Respondents' personal physicians), fell within ERISA § 1132(a)(1)(B). The Court therefore ruled these complaints were completely pre-empted by ERISA § 1132 and Removable to Federal District Court, therefore giving Federal Court Jurisdiction over resolution of the Complaints and defining ERISA as the law to be followed, superseding the applicable Texas statute (the THCLS). Consequently, the limited so-called "Equitable Remedies" available under ERISA § 1132 must be the exclusive remedies available to redress damage alleged to be suffered as a result of these Managed Care Utilization Review decisions.
The Supreme Court decision reversed a decision of the U.S. Court of Appeals for the 5th Circuit that ERISA did not preempt the state causes of action and could be Remanded to Texas State Court to be tried there under Texas law.

抄文引用元・出典: フリー百科事典『 ウィキペディア(Wikipedia)
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