ERISA blocks providers’ suit over La-Z-Boy plan reimbursement

Blue Cross paid $1,598.40, an amount the providers said was based on Medicare, not the rate they were promised. 

The providers sued La-Z-Boy and Blue Cross in March 2024, bringing state-law claims for negligent misrepresentation and promissory estoppel. They alleged the oral assurances were false and that they relied on them to provide care. 

The case never reached that question. A federal district court in Michigan dismissed the claims, ruling that ERISA preempted them. On August 19, 2026, the US Court of Appeals for the Sixth Circuit agreed. 

ERISA displaces state-law claims that “relate to” an employer benefit plan. Applying its 1991 Cromwell decision, the court held that provider claims built on a plan administrator’s assurances about coverage or reimbursement terms fall within that bar, whatever label the claims carry. Because the providers’ claims turned on the terms of La-Z-Boy’s plan, they were preempted. 

For employers that sponsor ERISA health plans and the companies that administer them, the decision reaffirms that shield within the Sixth Circuit. Out-of-network providers cannot use state misrepresentation law to recover the gap between what they were told by phone and what a plan actually paid. The court marked the opinion for publication, making it binding precedent in the circuit.