Metropolitan Life Insurance Co. v. Massachusetts (and Travelers Insurance Company v. Massachusetts)

471 U.S. 724
Brief Filed: 1/85
Court: Supreme Court of the United States
Year of Decision: 1985

Read the full-text amicus brief (PDF, 537KB)

Issue

Whether a state law requiring mandatory minimal mental health benefits under which outpatient services could be provided by a licensed psychologist was preempted by the federal ERISA law

Index Topics

ERISA; Psychologists' Scope of Practice/Reimbursement for "Mental Health Services"

Facts

A Massachusetts statute required that certain mental health benefits be provided to Massachusetts residents insured under general health insurance policies or employee health care plans that cover hospital and surgical expenses. The State of Massachusetts brought suit to enforce the statute. The insurance companies argued that the provisions concerning employee plans were preempted by ERISA and the National Labor Relations Act. The Massachusetts Superior Court issued a preliminary injunction requiring that the insurance companies provide the coverage and a later judge issued a permanent injunction to the same effect. The insurance companies applied for a direct appeal to the Supreme Judicial Court of Massachusetts which was granted. The Massachusetts Supreme Judicial Court affirmed upholding the Massachusetts statute and finding no preemption by ERISA and/or the National Labor Relations Act. The insurance companies appealed to the U.S Supreme Court.

APA's Position

APA submitted an amicus brief arguing that: (1) ERISA was not intended to preempt mandated benefit statutes because arguably (a) the Massachusetts statute relates to employee benefit plans governed by ERISA and regulates insurance, and is therefore excepted from ERISA's preemption provision, and (b) the Massachusetts statute does not fall within the scope of the deemer provision; (2) the McCarran-Ferguson Act was intended to preserve mandated benefit statutes, as the relevant case law and legislative history compel the conclusion that the statute regulates the business of insurance; and (3) appellants' narrow reading of the insurance savings clause was unsupportable in light of the statutory language, legislative history, judicial construction and relevant policy considerations of the relevant statutes.

Results

The U.S. Supreme Court decided in favor of the position advocated by APA — the minimum mental health benefits law was not preempted by ERISA. The Court pointed out that the savings clause precluded preemption.