Thomas J. Knolmayer, M.D., Alaska Trauma and Acute Care Surgery, LLC. v. Charina McCollum and Jason McCollum

Summary

The Alaska Supreme Court held that a self‑funded employer health plan governed by ERISA is not a “federal program” for purposes of AS 09.55.548(b), so the statute’s collateral‑source reduction applies, bars the plaintiff from recovering amounts paid by the plan, is not preempted by ERISA, and violates the Alaska Constitution’s equal‑protection guarantee when applied to claimants whose insurer has contractual subrogation rights. The court vacated the lower court’s order and remanded for further proceedings.