FMS Nephrology Partners North Central Indiana Dialysis Centers, LLC v. Meritain Health, Inc.

Summary

The Indiana Supreme Court held that FMS's state-law claims against ERISA-governed health plans were not completely preempted because FMS pursued independent contract rights rather than assigned rights to plan benefits, and the network agreements imposed independent legal duties. The court further held that conflict preemption and summary judgment could not be resolved on the record because a factual dispute remained over whether the disputed services were covered and whether the plans paid less than separately negotiated provider rates. The court granted transfer, vacated the summary judgment, and remanded for further proceedings.