Board of Trustees of the Glazing Health and Welfare Trust v. Chambers

Nevada Senate Bill 223, which limits damages that can be collected from general contractors and imposed notification requirements on contractors and welfare benefit plans, was a legitimate exercise of Nevada's traditional state authority and was not preempted by the Employee Retirement Income Security Act (ERISA).The Ninth Circuit vacated the district court's grant of summary judgment to plaintiffs. Determining that the appeal was not moot, the panel held that SB 223 was not preempted because it did not intrude on any federally regulated field, conflict with ERISA's objectives, or otherwise impermissibly relate to ERISA plans. Rather, SB 223 targeted an area of traditional state concern—debt collection—and pared back a state-conferred entitlement to collect unpaid debts from third-party general contractors. Therefore, SB 223 was a legitimate exercise of Nevada's traditional state authority. View "Board of Trustees of the Glazing Health and Welfare Trust v. Chambers" on Justia Law