Metropolitan Life v. Massachusetts
Annotate this Case
471 U.S. 724 (1985)
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U.S. Supreme Court
Metropolitan Life v. Massachusetts, 471 U.S. 724 (1985)
Metropolitan Life Insurance Co. v. Massachusetts
Argued February 26, 1985
Decided June 3, 1985*
471 U.S. 724
A Massachusetts statute (§ 47B) requires that certain minimum mental health care benefits be provided a Massachusetts resident who is insured under a general health insurance policy or an employee health care plan that covers hospital and surgical expenses. Appellant insurer in No. 84-325 contends that § 47B, as applied to insurance policies purchased by employee health care plans regulated by the federal Employee Retirement Income Security Act of 1974 (ERISA), is preempted by that Act. Section 514(a) of ERISA provides that the statute shall "supersede any and all State laws insofar as they may now or hereafter relate to any employee benefit plan." But § 514(b)(2)(A) provides that, with one exception, nothing in ERISA "shall be construed to exempt or relieve any person from any law of any State which regulates insurance." The one exception is found in § 514(b)(2)(B), which states that no employee benefit plan
"shall be deemed to be an insurance company or other insurer . . . or to be engaged in the business of insurance . . . for purposes of any law of any State purporting to regulate insurance companies [or] insurance contracts."
Appellant insurer in No. 84-356 contends that § 47B, as applied to insurance policies purchased pursuant to collective bargaining agreements regulated by the National Labor Relations Act (NLRA), is preempted by that Act, because it effectively imposes a contract term on the parties that otherwise would be a mandatory subject of collective bargaining. Massachusetts brought an action in Massachusetts Superior Court to enforce § 47B against appellant insurers, and that court issued an injunction requiring the insurers to provide the coverage mandated by § 47B. The Massachusetts Supreme Judicial Court affirmed, finding no preemption under either ERISA or the NLRA.
1. Section 47B, as applied, is a law "which regulates insurance" within the meaning of § 514(b)(2)(A), and therefore is not preempted by
§ 514(a) as it applies to insurance contracts purchased for plans subject to ERISA. Section 514(b)(2)(A)'s plain language, its relationship to the other ERISA preemption provisions, and the traditional understanding of insurance regulations, all lead to the conclusion that mandated benefit laws such as § 47B are saved from preemption by the operation of § 514(b)(2)(A). Nothing in ERISA's legislative history suggests a different result. Pp. 471 U. S. 739-747.
2. Nor is § 47B, as applied to a plan negotiated pursuant to a collective bargaining agreement subject to the NLRA, preempted by the NLRA. Pp. 471 U. S. 747-758.
(a) The NLRA preemption involved here is the one that protects against state interference with policies implicated by the structure of the NLRA itself, by preempting state law and state causes of action concerning conduct that Congress intended to be unregulated. Pp. 471 U. S. 747-751.
(b) Such preemption rests on a sound understanding of the NLRA's purpose and operation that is incompatible with the view that the NLRA preempts any state attempt to impose minimum benefit terms on the parties to a collective bargaining agreement. Pp. 471 U. S. 751-753.
(c) Minimum state labor standards affect union and nonunion employees equally, and neither encourage nor discourage the collective bargaining processes that are the subject of the NLRA. Nor do they have any but the most indirect effect on the right of self-organization established in the NLRA. Unlike the NLRA, mandated benefit laws such as § 47B are not designed to encourage or discourage employees in the promotion of their interests collectively; rather, they are in part designed to give minimum protections to individual employees and to ensure that each employee covered by the NLRA receives mandated health insurance coverage. These laws are minimum standards independent of the collective bargaining process. Pp. 471 U. S. 753-756.
(d) There is no suggestion in the NLRA's legislative history that Congress intended to disturb the state laws that set minimum labor standards but were unrelated to the collective bargaining or self-organization processes. To the contrary, Congress in the NLRA developed the framework for self-organization and collective bargaining within the larger body of state law promoting public health and safety. When a state law establishes a minimal employment standard not inconsistent with the NLRA's general goals, it conflicts with none of the NLRA's purposes. Section 47B is an insurance regulation designed to implement the Commonwealth's policy on mental health care, and as such is a valid and unexceptional exercise of the Commonwealth's police power. Though § 47B potentially limits any employee's right to choose one thing by requiring that he be provided with something else, it does
not limit the right of self-organization or collective bargaining protected by the NLRA. Pp. 471 U. S. 756-758.
391 Mass. 730, 46:3 N.E.2d 548, affirmed.
BLACKMUN, J., delivered the opinion of the Court, in which all other Members joined, except POWELL, J., who took no part in the decision of the cases.