Section II, Part A of this Note will discuss the history of ERISA law, including a look at what Congress intended to achieve in enacting such a broadly preemptive doctrine. Parts B and C will explain the complicated and highly technical provisions that make up ERISA as it pertains to health care benefits law. Finally, Part D will navigate several key cases leading up to the Rush decision and explain how each case contributed to the Court's decision. Following the background of ERISA law, Section III will discuss the facts of the Rush case, charting the journey that brought this issue to the United States Supreme Court and taking the reader through the reasoning of the Court. Section IV is an analysis of the Rush decision. The first part of the analysis explains why the Rush decision produced the correct outcome in view of five specific factors: (1) HMOs should not have the ability to reserve absolute discretion without limits; (2) the doctor-patient relationship has been destroyed in the managed care era; (3) there is no fear that patients will yield outrageous damage awards that would cause HMOs to go bankrupt; (4) Pegram still stands for the proposition that patients cannot sue HMOs for having a profit motive; and (5) the uniformity that Congress sought to maintain is still intact. The second step in the analysis is to explain why some people worry that the decision in Rush is not enough to protect millions of patients. Finally, in Section IV, Part C, there is a discussion of recent rulings interpreting and applying the rules supplied by the Rush Court.

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