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Kress v. Food Employers Labor Relations Ass'n

D. Md.September 6, 2002No. Civ.A. DKC2002-2159Cited 6 times
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Case Details

Judge(s)
Chasanow
Status — whether other courts must follow this ruling
Published
Procedural Posture — the stage the case had reached
motion to dismiss

Related Laws

No specific laws identified for this ruling.

Claim Types

Breach of Contract

Outcome

The court granted Giant of Maryland's motion to dismiss the plaintiff's state law breach of contract claim, finding that it was preempted by ERISA's expansive preemption clause because the claim sought to recover benefits already provided by an ERISA-governed welfare benefit plan.

What This Ruling Means

**Kress v. Food Employers Labor Relations Association** This case involved an employee who sued Giant of Maryland grocery stores for breach of contract, claiming the company failed to provide certain benefits or compensation that were promised. The worker tried to use state law to pursue their claim against the employer. The court sided with Giant of Maryland and dismissed the employee's lawsuit entirely. The judge ruled that the worker's state law claim was "preempted" - meaning it was blocked - by a federal law called ERISA (Employee Retirement Income Security Act). The court found that since the benefits the employee was seeking were already covered by an ERISA-governed benefit plan, they couldn't sue under state law for the same benefits. **What this means for workers:** This ruling shows how federal ERISA law can limit workers' ability to sue employers in state court over benefit disputes. When your employer provides benefits through an ERISA plan (like health insurance, retirement plans, or welfare benefits), you may be restricted to filing claims through the federal ERISA process rather than using potentially more favorable state laws. This can make it harder for employees to recover damages since ERISA typically offers more limited remedies than state courts.

This summary was generated to explain the ruling in plain English and is not legal advice.

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This ruling information is sourced from public court records via CourtListener.com. Case outcomes, claim types, and summaries are extracted using AI analysis and may be incomplete or inaccurate. It is provided for informational and educational purposes only and does not constitute legal advice.

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