Eric L. Patterson, on behalf of himself and all others similarly situated v. Unitedhealth Group, Inc.

RECOMMENDED FOR PUBLICATION
Pursuant to Sixth Circuit I.O.P. 32.1(b)
File Name: 25a0327p.06
UNITED STATES COURT OF APPEALS
FOR THE SIXTH CIRCUIT
ERIC L. PATTERSON, on behalf of himself and all
others similarly situated,
Plaintiff-Appellant,
v.
UNITEDHEALTH GROUP, INC.; UNITED HEALTHCARE
SERVICES, INC.; UNITED HEALTHCARE INSURANCE
COMPANY; OPTUM, INC.; SWAGELOK COMPANY,
Defendants-Appellees.
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No. 25-3175
Appeal from the United States District Court for the Northern District of Ohio at Cleveland.
No. 1:23-cv-00378—J. Philip Calabrese, District Judge.
Decided and Filed: December 2, 2025
Before: SILER, NALBANDIAN, and READLER, Circuit Judges.
_________________
COUNSEL
ON BRIEF: Patrick J. Perotti, Patrick J. Brickman, DWORKEN & BERNSTEIN CO., L.P.A.,
Painesville, Ohio, Benjamin P. Pfouts, THE HENRY FIRM, Chagrin Falls, Ohio, for Appellant.
Wesley E. Stockard, LITTLER MENDELSON, P.C., Atlanta, Georgia, Noah G. Lipschultz,
LITTLER MENDELSON, P.C., Minneapolis, Minnesota, for Appellees.
_________________
OPINION
_________________
READLER, Circuit Judge. Eric Patterson has had a long-running dispute with
UnitedHealth Group, his insurer and health plan administrator. In short, Patterson claims that
United collected reimbursement for medical expenses paid on Patterson’s behalf even though his
health plan gave United no such right. For that reason, Patterson sued United and others under
>

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the Employee Retirement Income Security Act of 1974 (ERISA). The district court dismissed
those claims, and we largely affirmed the district court on appeal. See Patterson v. United
HealthCare Ins. Co., 76 F.4th 487 (6th Cir. 2023). While that appeal was pending, however,
Patterson filed an action in state court asserting state law claims against defendants that echoed
in substance his federal claims. Defendants removed on the grounds that ERISA completely
preempted Patterson’s state law claims and sought dismissal of what it viewed to be a lawsuit
duplicative of its federal case. The district court again granted dismissal, and Patterson again
appealed. We agree with the district court and affirm.
I.
We adopt our previous statement of the facts, which we summarize here. See Patterson,
76 F.4th at 491–92. United provided health insurance to Patterson and his wife through
Patterson’s employer, Swagelok Company. As ERISA governed Patterson’s health plan, see 29
U.S.C. §§ 1101, 1103(a), United, in accordance with ERISA requirements, delivered to Patterson
a summary plan description, which offered a synopsis of his plan’s terms. See id. § 1022(a).
Patterson, however, did not receive a copy of the full plan document.
According to the plan summary, if Patterson recovered from a third party for an insured
incident, the plan had a right to claim reimbursement from that recovery. That language came to
the fore when Patterson sustained injuries in a collision with a semi-truck. United covered his
accident-related medical bills as required. At the same time, Optum, United’s agent and
subsidiary, informed Patterson that it would invoke the plan’s reimbursement rights if he
recovered from the other driver. To that end, Patterson sued the other driver’s employer in state
court and, within the same action, sought declaratory judgment against the plan as to
reimbursement. During the litigation, Patterson alleged that United falsely claimed that a full
plan document did not exist. Ultimately, Patterson recovered from the other driver’s employer,
and, in so doing, struck an agreement to pay his plan $25,000 in reimbursement.
Ordinarily, that would have settled the matter. But as fate would have it, Patterson’s wife
sustained injuries in an unrelated traffic accident just months after her husband. Things went for
Ms. Patterson much like they did for Mr. Patterson: United paid the medical bills, Optum

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No. 25-3175 Patterson v. UnitedHealth Group, Inc., et al. Page 3
notified the Pattersons about reimbursement, and Patterson’s wife sued the other driver in state
court while simultaneously seeking a declaratory judgment against the plan. This time, however,
United produced in discovery the very plan document it had previously claimed not to exist. The
newly revealed plan document stated that it controlled in case of any discrepancy between it and
the plan summary. And, unlike the summary, the document had nothing to say about a
reimbursement obligation on the Pattersons’ part. On that basis, the state court entered a
declaratory judgment in Ms. Patterson’s favor, holding that the Pattersons’ plan did not allow
United to collect reimbursement. The Ohio Court of Appeals affirmed. Patterson v. Am. Fam.
Ins. Co., 178 N.E.3d 573, 581 (Ohio Ct. App. 2021).
With his plan document in hand, Patterson sued United, Optum, Swagelok, and others
under ERISA’s civil enforcement provision, 29 U.S.C. § 1132(a), alleging that defendants
defrauded him out of the $25,000 he previously paid in reimbursement. The district court
granted defendants’ motion to dismiss on standing grounds and for failure to state a claim.
Patterson v. UnitedHealthcare Ins. Co. (Patterson I), No. 21-cv-470, 2022 WL 279952, at *5, 7
(N.D. Ohio Jan. 31, 2022). Patterson appealed. We mostly affirmed the dismissal of his claims,
allowing only his ERISA claim under § 1132(a)(3) to proceed. Patterson, 76 F.4th at 500. The
action remains pending before the district court on remand. Id.; see Patterson v.
UnitedHealthcare Ins. Co. (Patterson II), 762 F. Supp. 3d 643, 666 (N.D. Ohio 2025).
That takes us to the present lawsuit and its relationship to the first. In Patterson’s earlier
case, the district court dismissed Patterson’s federal claims on the merits, and, as a result,
declined to exercise supplemental jurisdiction over the state law claims. Patterson I, 2022 WL
279952, at *7–9. While our ruling on Patterson’s first appeal was pending, he refiled his state
law claims in state court, naming United, Optum, and Swagelok as defendants. On behalf of
himself as well as two putative classes, Patterson asserted claims for fraudulent and negligent
misrepresentation, conversion, civil conspiracy, and unjust enrichment. Defendants removed the
action to federal court and sought dismissal; Patterson moved to remand.
The district court sided with defendants. In its view, Patterson’s state law claims were a
repackaged version of his still-pending ERISA lawsuit. Patterson II, 762 F. Supp. 3d at 665–66.
After all, the district court reasoned, both actions rested on the same factual events and sought

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the same outcome: a return of the $25,000 Patterson says he should not have had to pay because
of the plan’s terms. Id. As a result, the district court accepted defendants’ argument that ERISA
completely preempted Patterson’s state law causes of action. Id. Yet rather than direct Patterson
to replead his claims, the district court opted to dismiss the action outright. Id. Why? Patterson,
recall, already had one pending ERISA suit—the remand of his original appeal—and the district
court had just denied defendants’ motion to dismiss that action. Id. at 655–60. In place of
allowing duplicate lawsuits to proceed, the district court dismissed this later-filed action. Id. at
666. Patterson appealed, which brought the parties back before us.
II.
We review de novo both the district court’s refusal to remand and its dismissal of
Patterson’s complaint. City of Cleveland v. Ameriquest Mortg. Sec., Inc., 615 F.3d 496, 501–02
(6th Cir. 2010); Operating Eng’rs’ Loc. 324 Fringe Benefit Funds v. Rieth-Riley Constr. Co., 43
F.4th 617, 621 (6th Cir. 2022) (citing Loren v. Blue Cross & Blue Shield of Mich., 505 F.3d 598,
604 (6th Cir. 2007)). Taking Patterson’s well-pleaded factual allegations (and the reasonable
inferences therefrom) as true, we assess whether Patterson has plausibly shown entitlement to
relief. Forman v. TriHealth, Inc., 40 F.4th 443, 448 (6th Cir. 2022) (citing Bell Atl. Corp. v.
Twombly, 550 U.S. 544, 570 (2007)).
Turn, then, to Patterson’s appeal. To his mind, the district court first erred in deeming his
state law claims completely preempted by ERISA. As he sees it, those claims are wholly
independent causes of action that can proceed “side by side” with his parallel ERISA suit.
Appellant Br. 3.
At the outset, it bears addressing how we understand the notion of “complete
preemption.” Federal courts, it is well understood, have jurisdiction over only a limited set of
cases. One category of that jurisdiction is federal question jurisdiction, which covers “all civil
actions arising under” federal law. 28 U.S.C. § 1331. In determining what “arises under”
federal law, we follow the “well-pleaded complaint rule.” Aetna Health Inc. v. Davila, 542 U.S.
200, 207 (2004) (citation modified). That is, we look to what “necessarily appears” on the face

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of the plaintiff’s properly pleaded complaint to assess whether a claim under federal law has
been asserted. Id. (quoting Taylor v. Anderson, 234 U.S. 74, 75–76 (1914)).
ERISA, however, is a rare exception to the well-pleaded complaint rule. Gardner v.
Heartland Indus. Partners, LP, 715 F.3d 609, 612 (6th Cir. 2013). The law has such
“extraordinary pre-emptive power . . . that [it] converts an ordinary state common law complaint
into one stating a federal claim for purposes of the well-pleaded complaint rule.” Metro. Life
Ins. Co. v. Taylor, 481 U.S. 58, 65 (1987). In other words, “any state-law cause of action that
duplicates, supplements, or supplants the ERISA civil enforcement remedy” can be removed to
federal court, regardless of whether ERISA shows up on the face of the complaint. Davila, 542
U.S. at 209. Understood that way, complete preemption is better described as a jurisdictional
doctrine than a typical preemption defense. Hogan v. Jacobson, 823 F.3d 872, 879 (6th Cir.
2016) (recognizing the “misleadingly named doctrine” is “more aptly described as a
jurisdictional doctrine (citation modified)). We note that complete preemption differs from
“express preemption” under ERISA, the latter being a statutory creation that does afford a
traditional preemption defense, but not a basis for removal. See Gardner, 715 F.3d at 612 (citing
29 U.S.C. § 1144(a)). The parties agree that this appeal concerns only complete preemption.
With this understanding in mind, turn to the issue at hand: whether ERISA completely
preempts Patterson’s claims. The Supreme Court in Davila fashioned this inquiry into a two-
pronged test. Under Davila, ERISA completely preempts a state law claim if both (1) “the
plaintiff complains about the denial of benefits to which he is entitled ‘only because of the terms
of an ERISA-regulated employee benefit plan’”; and (2) “the plaintiff does not allege the
violation of any ‘legal duty . . . independent of ERISA or the plan terms.’” Gardner, 715 F.3d at
613 (quoting Davila, 542 U.S. at 210). As explained next, both prongs are met here.
A. Start with prong one. Our examination looks beyond the label placed on a state law
claim and instead asks whether it is “in essence” one “for the recovery of an ERISA plan
benefit.” K.B. ex rel. Qassis v. Methodist Healthcare – Memphis Hosps., 929 F.3d 795, 801 (6th
Cir. 2019) (citation modified). Put differently, “if an individual, at some point in time, could
have brought his claim under [§ 1132(a)],” then an action alleging essentially the same
wrongdoing meets Davila’s first prong, regardless of how it is packaged. Davila, 542 U.S. at

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210. Here, as in district court, defendants assert that Patterson’s claims replicate two claims
articulated in 29 U.S.C. § 1132(a): one, under § 1132(a)(1)(B), that a party may “recover
benefits due to him under the terms of his plan” and “enforce his rights under the terms of the
plan,” id.; and, two, that a party under § 1132(a)(3) may “enforce . . . the terms of the plan” or
“redress [ERISA] violations” like breach of fiduciary duty, id.
1. Take first § 1132(a)(1)(B). Although we have yet to address an on-all-fours case,
several of our sister circuits have done so. A collection of circuits has held that similar state law
challenges to an ERISA plan’s reimbursement rights are in essence disguised suits “to recover
benefits due” under § 1132(a)(1)(B). See Rudel v. Haw. Mgmt. All. Assoc., 937 F.3d 1262,
1270–71 (9th Cir. 2019) (citation modified); Wirth v. Aetna U.S. Healthcare, 469 F.3d 305, 309
(3d Cir. 2006); Levine v. United Healthcare Corp., 402 F.3d 156, 163 (3d Cir. 2005); Arana v.
Ochsner Health Plan, 338 F.3d 433, 438–39 (5th Cir. 2003) (en banc); Singh v. Prudential
Health Care Plan, Inc., 335 F.3d 278, 291 (4th Cir. 2003). But see Wurtz v. Rawlings Co., 761
F.3d 232, 242–43 (2d Cir. 2014). To be sure, several of these cases predate Davila. That said,
their analyses in effect answer the same question posed by Davila’s first prong. See Rudel, 937
F.3d at 1271 (citing these cases).
One particularly emblematic example is the Third Circuit’s decision in Wirth. See 469
F.3d at 306–07. Like Patterson, Wirth was injured in an auto accident and received medical care
covered by his insurer. Id. When he obtained a settlement from the other driver, his insurer
stepped in to demand reimbursement from those monies. Id. at 307. Wirth ultimately paid out a
sum to satisfy his insurer’s claim. Id. But Wirth disputed those reimbursement rights, and, like
Patterson, filed a class action in state court under state law claiming, among other things, that his
insurer had been “unjust[ly] enrich[ed]” by improperly collecting reimbursement. Id. The Third
Circuit disagreed, holding that Wirth’s state law theories were recycled § 1132(a)(1)(B) claims to
“recover benefits due” or to “enforce his rights under the terms of the plan.” Id. at 308–09
(quoting 29 U.S.C. § 1132(a)(1)(B)). And because Wirth sought to recover a portion of benefits
wrongfully taken from him, § 1132(a)(1)(B) completely preempted his claims. Id. Although
Wirth’s insurer initially paid his benefits in full by paying for his healthcare, the appeals court
reasoned that the insurer’s subsequent pursuit of reimbursement “resulted in diminished

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benefits” to Wirth. Id. at 309. In the court’s words, “[t]hat the bills and coins” used to reimburse
his insurer were not “literally the same as those used . . . to cover Wirth’s injuries is of no
import—‘the benefits are under something of a cloud.’” Id. (quoting Arana, 338 F.3d at 438).
Patterson raises the same objection as that raised in Wirth. As he sees things, he does not
seek to recover benefits under § 1132(a)(1)(B) because his “benefits were already paid” to him,
meaning “the obligation of the ERISA plan to provide benefits was over.” Appellant Br. 29
(citation modified). But it would be odd for complete preemption under ERISA—and thus our
subject matter jurisdiction—to hinge on “the fortuity of when a plan term was misapplied to
diminish the benefit.” Levine, 402 F.3d at 163 (quoting Singh, 335 F.3d at 291). For today’s
legal inquiry, it makes no practical difference whether the plan clawed back Patterson’s benefits
after paying for his care or simply withheld them until getting its claimed share of the recovery.
In either case, benefits are “due.” See Rudel, 937 F.3d at 1271 (“[Plaintiff] has not fully
recovered the benefits because he has not obtained the benefits free and clear of the plan’s
claims.” (citation modified)).
What is more, not only could Patterson have brought a § 1132(a)(1)(B) claim, but in fact
he also did bring one, albeit in his first federal lawsuit. There, Patterson leveled the same core
accusation that he levels here—that defendants tricked him into paying reimbursement using a
misleading plan summary. This reality only reinforces the conclusion that Patterson’s state
claims double as an ERISA claim “to recover benefits due to him” under § 1132(a)(1)(B). That
Patterson disavowed the theory in his earlier appeal makes no difference for our purposes.
Seeing things differently, Patterson emphasizes that ERISA neither requires nor prohibits
reimbursement, which, in his view, means that his claims do not implicate ERISA. But whether
ERISA speaks to reimbursement by its terms does not matter. Again, Davila asks whether
Patterson’s complaint arises from “the terms of [his] ERISA-regulated employee . . . plan.”
Davila, 542 U.S. at 210 (emphasis added). Just so here.
Patterson’s cited cases do not move the ball. He principally cites the Second Circuit’s
decision in Wurtz. See 761 F.3d at 242–43. There, the plaintiffs challenged their plan’s
reimbursement rights based on a state insurance statute. Id. at 242. The court of appeals held

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that Davila’s first prong was unmet because the plaintiffs’ claims were “based on a state law”
and not on any right provided “under the terms of their plans.” Id. (citation modified). We
cannot follow that lead. For one thing, Wurtz’s emphasis on the plaintiff’s claimed legal basis
for demanding benefits conflicts with our instruction to look to the “essence” of the claim. K.B.,
929 F.3d at 801 (citation modified). That point is better addressed, if anywhere, at Davila prong
two, which considers whether the state claim implicates a legal duty independent of ERISA or
the plan’s terms. See infra. For another, Wurtz assumed that complete preemption could not
apply because ERISA’s express preemption provision leaves a carve-out for state insurance
statutes. 761 F.3d at 242. That wrinkle does not appear here.
At any rate, it bears emphasizing that Wurtz rejected complete preemption because the
plaintiffs challenged their insurer’s reimbursement rights based upon a state statute. 761 F.3d at
242. They specifically did not “contend that they ha[d] a right to keep their tort settlements
under the terms of their plan[s].” Id. (citation modified). So too for Patterson’s other cited
cases. See Cmty. Ins. Co. v. Rowe, 85 F. Supp. 2d 800, 816 (S.D. Ohio 1999) (“general laws of
Ohio”); Cottrill v. Allstate Ins. Co., No. 2:09-cv-714, 2009 WL 3673017, at *3 (S.D. Ohio Oct.
30, 2009) (“Ohio common law”). Here, on the other hand, Patterson asserts that his entitlement
to benefits originates with the “terms and conditions” of his plan—not some freestanding source
of state law. R. 1-1, PageID 14–19. If anything, Patterson’s citations illustrate why this case
makes for a much easier call. In the end, we agree with defendants that Patterson’s claims meet
Davila’s first prong via § 1132(a)(1)(B).
2. The district court, for its part, did not consider preemption under § 1132(a)(1)(B), and
instead found Patterson’s claims encompassed by § 1132(a)(3). Patterson II, 762 F. Supp. 3d at
663–64. Section 1132(a)(3) allows plan beneficiaries to sue “to enforce . . . the terms of the
plan” and ERISA itself, id., including ERISA’s statutory fiduciary duties, §§ 1104, 1106.
Although we have not precisely considered whether complete preemption extends to
§ 1132(a)(3), we observe that both Davila and its forerunner, Taylor, refer to “[t]he pre-emptive
force” of § 1132(a) as a whole. Davila, 542 U.S. at 209; Taylor, 481 U.S. at 65–66; see also
Smith v. Provident Bank, 170 F.3d 609, 613 (6th Cir. 1999) (extending complete preemption to
§ 1132(a)(2), “see[ing] little reason to distinguish” it from § 1132(a)(1)(B)). And, we note, both

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parties presume that § 1132(a)(3) can completely preempt state law claims. See, e.g., Singh, 335
F.3d at 291; Trs. of N.Y. State Nurses Ass’n Pension Plan v. White Oak Glob. Advisors, LLC, 102
F.4th 572, 606 n.18 (2d Cir. 2024). That said, as we have already held that Patterson’s claims
satisfy Davila’s first prong via § 1132(a)(1)(B), we need not reach § 1132(a)(3).
B. Turn next to prong two: whether Patterson’s claims implicate a duty “independent of
ERISA or the plan terms.” Gardner, 715 F.3d at 613 (quoting Davila, 542 U.S. at 210). In
employing the phrase “independent,” Davila did not just mean that the duty “nominally arises
from a source other than the plan’s terms.” Id. Rather, a duty in this setting is “independent”
only if it is “not derived from, or conditioned upon, the terms of the [plan]” and “nobody needs
to interpret the plan to determine whether that duty exists.” Id. at 614 (citing Davila, 542 U.S. at
210).
Each of defendants’ alleged breaches of duty rests entirely upon what Patterson’s ERISA-
governed plan does (or does not) say. Start with his fraud claim. Patterson alleges that
defendants falsely represented that he “had agreed to provide [reimbursement] rights” in his plan
and that defendants either knew that was false or had “negligently failed to read or review the
underlying plan document to confirm.” R. 1-1, PageID 22–23. In other words, the rights and
duties set forth in Patterson’s plan are the very basis of the fraud alleged. Patterson counters that
the “dut[y] to not defraud” exists on its own. Reply Br. 9. True enough. Yet that duty is only
“nominally” independent here. Gardner, 715 F.3d at 613. Defendants’ duty not to misrepresent
the parties’ obligations under the plan, of course, could not exist absent the plan and its terms.
Patterson’s other causes of action go the same way. For conversion, Patterson alleges, as
he must, that he “had the right to possession of the money [he] paid [d]efendants.” R. 1-1,
PageID 25. Yet defendants did not “wrongful[ly]” interfere with that right if his plan imposed a
duty to reimburse. Zipkin v. FirstMerit Bank N.A., 176 N.E.3d 86, 97 (Ohio Ct. App. 2021). As
for unjust enrichment, Patterson dropped that claim in the district court, but it goes without
saying that no one was “unjustly” enriched at Patterson’s expense if he did, in fact, owe
reimbursement under the plan. Last is civil conspiracy. This is not a separate tort; instead, it
requires an actionable “underlying tort.” Addison Holdings, LLC v. Fox, Byrd & Co., 203

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N.E.3d 1259, 1286 (Ohio Ct. App. 2022). Patterson concedes that this theory rises or falls with
his others, and we find that they all fall under Davila’s second prong.
Patterson resists this conclusion in a few ways. None are availing. He first claims that
the circumstances of his case obviate any “need[] to interpret the plan.” Gardner, 715 F.3d at
614. According to Patterson, defendants only lied about the “existence” of the plan document,
not its “meaning.” Reply Br. 2. We disagree. Upon discovery of the plan document’s
“existence,” the state court had to spill ink ascertaining its “meaning” in relation to the allegedly
fraudulent plan summary. See Patterson v. Am. Fam. Ins. Co., 178 N.E.3d 573, 578–81 (Ohio
Ct. App. 2021). Patterson also insists that this prior state court ruling as to reimbursement means
that a federal court need not consult the plan to rule in his favor. This point too misses the mark.
Regardless of procedural history, for Patterson’s claims to go on, a court—whether an Ohio court
or elsewhere—must interpret his ERISA plan and determine whether it created a duty to provide
reimbursement-free benefits. That is, “[some]body needs to interpret the plan.” Gardner, 715
F.3d at 614.
Patterson also posits that there is something special about common law fraud claims like
his—namely, that stopping fraudsters is a “field[] of traditional state regulation” into which
Congress presumptively did not mean to intrude. Appellant Br. 22–25 (quoting N.Y. State Conf.
of Blue Cross & Blue Shield Plans v. Travelers Ins. Co., 514 U.S. 645, 654 (1995)). But to the
extent such a presumption even exists, it has not been discussed in reference to complete
preemption under ERISA. See Gobeille v. Liberty Mut. Ins. Co., 577 U.S. 312, 325–26 (2016)
(casting doubt on this presumption with respect to express preemption). By contrast, we can and
routinely do find common law fraud claims completely preempted. See, e.g., Briscoe v. Fine,
444 F.3d 478, 500 (6th Cir. 2008) (“fraud, misrepresentation, and concealment”); Arora v. Henry
Ford Health Sys., No. 17-2252, 2018 WL 3760888, at *3 (6th Cir. July 9, 2018) (“fraud and
fraudulent concealment”).
Lastly, Patterson marshals a series of decisions in which fraud-based claims evaded
complete preemption. But those cases only go to show why this one meets Davila’s second
prong. Other than Wurtz, Patterson cites no case where a reimbursement dispute flunked
Davila’s second prong. And, as discussed, we find Wurtz distinguishable and the decisions of

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other courts better reasoned in any event. See Rudel, 937 F.3d at 1271 & n.5 (finding
reimbursement dispute met Davila’s second prong and distinguishing Wurtz); Noetzel v. Haw.
Med. Serv. Ass’n, 183 F. Supp. 3d 1094, 1107–08, 1110–11 (D. Haw. 2016) (same).
All things considered, we agree with the district court in holding that Patterson’s claims
meet both Davila prongs and are thus completely preempted by ERISA.
III.
That leaves us with one last housekeeping matter. We mentioned earlier that complete
preemption by itself does not result in dismissal of the “preempted” claims. Ordinarily, the
district court can direct the plaintiff to amend the complaint, or the plaintiff can simply recast the
existing pleading as one asserting § 1132(a) claims. See Hogan, 823 F.3d at 884. Here,
however, the district court dismissed the action altogether. Patterson II, 762 F. Supp. 3d at 665–
66.
We see no misstep in that approach. Although one could recharacterize Patterson’s
claims under § 1132(a), the district court was not required to do so. Patterson raised a
§ 1132(a)(1)(B) claim in his original federal action, and we previously found that he had
“disavow[ed]” it during his first appeal. Patterson, 76 F.4th at 495. Patterson likewise
maintains in this action that he could not have brought a § 1132(a)(1)(B) claim. Having
“disclaimed reliance” on the claim, he cannot assert it now. See Matthews v. Centrus Energy
Corp., 15 F.4th 714, 727 (6th Cir. 2021). As for § 1132(a)(3), the provision upon which the
district court based its refusal to remand to state court, Patterson’s original federal action—now
before the district court on remand—currently asserts that cause of action. To let Patterson
replead his state law claims under ERISA would thus result in duplicative proceedings before the
same court. In that situation, district courts enjoy the discretion over their dockets to dismiss
duplicate cases. See Waad v. Farmers Ins. Exch., 762 F. App’x 256, 260 (6th Cir. 2019) (citing
Smith v. SEC, 129 F.3d 356, 361 (6th Cir. 1997)). Indeed, given that Patterson’s state law claims
“aris[e] from the same set of facts,” the district court may have had this option from the start.
Church Joint Venture, L.P. v. Blasingame, 817 F. App’x 142, 146 (6th Cir. 2020) (quoting Ellis
v. Gallatin Steel Co., 390 F.3d 461, 479 (6th Cir. 2004) (explaining a district court’s power to

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dismiss an action when the plaintiff has engaged in “claim-splitting”). Equally true, Patterson
does not fault the district court for dismissing this later-filed action. Neither do we.
* * * * *
We affirm.

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