Manuel Galo, as Executor of the Estate of Ilda Galo v. Qualcare PPO

NOT FOR PUBLICATION UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY MANUEL GALO, as Executor of the Estate of ILDA GALO, Civil Action No. 25-14338 (SDW) (AME) Plaintiff, v. WHEREAS OPINION

QUALCARE PPO, January 28, 2026 Defendant.

WIGENTON, District Judge.

THIS MATTER having come before this Court upon Defendant Cigna Health and Life Insurance Company’s, improperly pled as “QualCare PPO,” (“Defendant”) Motion to Dismiss (D.E. 9) Plaintiff Manuel Galo’s, as Executor of the Estate of Ilda Galo, (“Plaintiff”) Complaint (D.E. 1 (“Compl.”)), and this Court having reviewed the Defendant’s submissions, noting that it is unopposed; and WHEREAS the Employee Retirement Income Security Act (“ERISA”) established federal causes of action in 29 U.S.C. § 1132(a) that preempt conflicting state laws, and it also contains a broad preemption provision in 29 U.S.C. § 1144(a) stating that ERISA “supersede[s] any and all State laws insofar as they may now or hereafter relate to any employee benefit plan.” 29 U.S.C. § 1144(a); Aetna Health Inc. v. Davila, 542 U.S. 200, 208–09 (2004); see also Plastic Surgery Ctr., P.A. v. Aetna Life Ins. Co., 967 F.3d 218, 226 (3d Cir. 2020).

WHEREAS courts routinely hold that when a party challenges the denial of ERISA benefits, but restyles those claims as common-law causes of action based on breach of contract, the implied covenant of good faith and fair dealing, promissory estoppel, or quantum meruit, those claims are preempted. See Gotham City Orthopedics, LLC v. Aetna Inc., No. 20-14915, 2021 WL 1541069, at *2 (D.N.J. Apr. 19, 2021). Here, Defendant alleges that the healthcare plan at issue is governed by ERISA and Plaintiff does not dispute this fact. Accordingly, Plaintiff’s state law claims for breach of contract and punitive damages are preempted by ERISA because the health care plan at issue is governed by ERISA and Plaintiff’s claims clearly relate to the ERISA Plan; therefore Defendant’s Motion to Dismiss is GRANTED and the complaint is DISMISSED WITH PREJUDICE. An appropriate order follows. /s/ Susan D. Wigenton x SUSAN D. WIGENTON, U.S.D.J.

Orig: Clerk cc: Parties André M. Espinosa, U.S.M.J.