Laurel Hill Mgmt. Servs., Inc v. La-Z-Boy Inc.

Summary

The court affirmed dismissal of the medical providers’ negligent-misrepresentation and promissory-estoppel claims because they were expressly preempted by ERISA. The claims depended on oral representations about the reimbursement terms of an ERISA plan and sought payment at a rate allegedly promised under that plan. The court also held that the providers forfeited and, in any event, were not entitled to leave to amend because they supplied neither the substance nor grounds of a proposed amendment. A separate concurrence is not included because no separate-opinion record was provided.