Jeffrey M. Ahn, Md v. Cigna Health

PRECEDENTIAL
UNITED STATES COURT OF APPEALS
FOR THE THIRD CIRCUIT
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No. 25-1723
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JEFFREY M. AHN, MD,
Appellant
v.
CIGNA HEALTH AND LIFE INSURANCE
COMPANY; JANE DOES 1-10;
ABC CORPORATIONS 1-10
____________
On Appeal from the United States District Court
for the District of New Jersey
(D.C. No. 2:19-cv-07141)
District Judge: Honorable Evelyn Padin
____________
Submitted Under Third Circuit L.A.R. 34.1(a)
March 24, 2026
Before: HARDIMAN, SCIRICA, and AMBRO, Circuit
Judges
(Filed: June 24, 2026 )

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____________
OPINION OF THE COURT
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HARDIMAN, Circuit Judge.
This appeal raises a question of first impression for this
Court: does the Employee Retirement Income Security Act of
1974 (ERISA) preempt a healthcare provider’s defamation
claim based on allegedly false statements in explanation of
benefits (EOB) forms sent to beneficiaries? We hold that it
does.
I
Appellant Dr. Jeffrey M. Ahn is an otolaryngologist
licensed to practice medicine in New Jersey and New York.
Appellee Cigna Health and Life Insurance Company is a
subsidiary of the Cigna Group. Though Dr. Ahn is not part of
Cigna’s provider network, some of his patients are insured by
Cigna. And when Dr. Ahn treats them, he submits claims to
Cigna. All of Cigna’s health insurance plans are governed by
ERISA.1
Dr. Ahn alleged that Cigna denied his claims about 50
times. In doing so, Cigna issued forms explaining why the
claims were denied. Many of these forms stated that the claims
were denied because Cigna did not pay for services performed
1 In the District Court, Dr. Ahn “disagree[d]” that the plans
were governed by ERISA. See App. 114. The Court found
otherwise, and Dr. Ahn does not challenge that determination
on appeal.

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by unlicensed providers—i.e., that Dr. Ahn was not licensed to
practice medicine. After he appealed the denials, Cigna
allowed them in whole, in part, or denied them for a reason
unrelated to his licensed status.
Dr. Ahn filed a three-count complaint in New Jersey
Superior Court, asserting claims for defamation, defamation
per se, and tortious interference. After Cigna removed the case
to federal court, it moved to dismiss, or in the alternative for
summary judgment, citing ERISA preemption and the statute
of limitations. See Ahn v. Cigna Health & Life Ins. Co., 2019
WL 5304628, at *4–5 (D.N.J. Oct. 21, 2019). The District
Court deferred ruling on the ERISA preemption defense at that
time because it could not “determine from the Complaint
which of the . . . allegedly defamatory EOBs relate to Cigna’s
administration of plans covered by ERISA.” Id. at *4.
Following discovery, Cigna moved for summary
judgment on all of Dr. Ahn’s claims, again citing ERISA
preemption. In response, Dr. Ahn withdrew his defamation and
tortious interference claims, so only his defamation per se
claim remained.
The District Court granted Cigna’s motion. The Court
first addressed whether ERISA governed the plans. Cigna
submitted documents showing that the plans were “governed
by ERISA, include information required by ERISA (including
the plan sponsor’s Employer Identification Number), and
explain beneficiaries’ rights under ERISA (including the right
to bring an action under ERISA § 502(a), 29 U.S.C.
§ 1132(a)).” Ahn v. Cigna Health & Life Ins. Co., 2025 WL
830217, at *4 (D.N.J. Mar. 17, 2025). Dr. Ahn offered no
record evidence to the contrary. So with one exception not
relevant here, the Court found that the plans were governed by

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ERISA because they were “established or maintained by an
employer for the purpose of providing . . . benefits.” Id.
The District Court then held that Dr. Ahn’s defamation
per se claim was preempted by ERISA. As the Court explained,
Dr. Ahn’s “claims arise from a central matter of plan
administration” because they were “premised on statements
made in EOBs sent to beneficiaries of ERISA plans” and
because “[t]hose EOBs were sent pursuant to Cigna’s
obligations under ERISA to provide written notice to patients
whose claims were denied, including the specific reasons for
the denial.” Id. at *6.
Dr. Ahn timely appealed.
II2
Section 514(a) of ERISA preempts “any and all State
laws insofar as they may now or hereafter relate to any
employee benefit plan” governed by the statute. 29 U.S.C.
§ 1144(a) (emphasis added). According to the language of
ERISA, “State law” includes “all laws, decisions, rules,
regulations, or other State action having the effect of law, of
any State.” Id. § 1144(c)(1). Because state common-law claims
2 The District Court had subject matter jurisdiction under 28
U.S.C. § 1332(a)(1). We have jurisdiction under 28 U.S.C.
§ 1291. We review the District Court’s summary judgment de
novo, applying the same standard it applied. See Kelly v.
Borough of Carlisle, 622 F.3d 248, 253 (3d Cir. 2010).
Summary judgment is warranted when, viewing the evidence
in the light most favorable to the non-movant, there are no
genuine issues “as to any material fact and the movant is
entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a).

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fall within this broad definition, they are often preempted by
ERISA. See, e.g., Ingersoll-Rand Co. v. McClendon, 498 U.S.
133, 140 (1990); Pilot Life Ins. Co. v. Dedeaux, 481 U.S. 41,
48 (1987). The term “relate to” in § 514(a) also is “deliberately
expansive.” Ingersoll-Rand, 498 U.S. at 138 (citation omitted);
see also Pilot Life, 481 U.S. at 45–46 (ERISA’s “express pre-
emption provisions” are “designed to ‘establish pension plan
regulation as exclusively a federal concern.’” (citation
omitted)). This does not mean that § 514(a)’s broad scope
should “extend to the furthest stretch of its indeterminacy”;
otherwise, “for all practical purposes pre-emption would never
run its course.” New York State Conf. of Blue Cross & Blue
Shield Plans v. Travelers Ins. Co., 514 U.S. 645, 655 (1995).
So preemption does not apply if the state claim “has only a
‘tenuous, remote, or peripheral’ connection with covered
plans, as is the case with many laws of general applicability.”
District of Columbia v. Greater Wash. Bd. of Trade, 506 U.S.
125, 130 n.1 (1992) (citation omitted).
“Implementing these principles,” the Supreme Court
“has described two categories of state laws that ERISA pre-
empts.” Gobeille v. Liberty Mut. Ins. Co., 577 U.S. 312, 319
(2016). “First, ERISA pre-empts a state law if it has a
‘reference’ to ERISA plans,” that is, where it “acts
immediately and exclusively upon ERISA plans or . . . where
the existence of ERISA plans is essential to the law’s
operation.” Id. at 319–20 (citations omitted). Second, “ERISA
pre-empts a state law that has an impermissible ‘connection
with’ ERISA plans.” Id. at 320 (citation omitted). A state law
can have an impermissible “connection with” an ERISA plan
if it “governs . . . a central matter of plan administration,” or
“interferes with nationally uniform plan administration.” Id.
(citation omitted).

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Cigna contends that Dr. Ahn’s per se defamation claim
falls in the second category of state laws that are preempted by
ERISA: laws that govern, or interfere with the uniformity of,
plan administration and so have an impermissible “connection
with” ERISA plans. We agree.
We have observed that “[t]he ‘connection with’
component of this test . . . supplies scarcely more content than
the ‘relate to’ formulation.” Nat’l Sec. Sys., Inc. v. Iola, 700
F.3d 65, 83–84 (3d Cir. 2012). So we must “also look to ‘the
objectives of the ERISA statute as a guide to the scope of the
state law that Congress understood would survive,’ as well as
to the nature of the effect of the state law on ERISA plans.” Id.
at 84 (quoting Cal. Div. of Lab. Standards Enf’t v. Dillingham
Constr., N.A., Inc., 519 U.S. 316, 325 (1997)); accord
Gobeille, 577 U.S. at 320. Those considerations lead us to
conclude that Dr. Ahn’s defamation per se claim is preempted
by ERISA. See 29 U.S.C. § 1001(a)–(b) (Relevant statutory
objectives include establishing uniform national safeguards
“with respect to the establishment, operation, and
administration of [employee benefit] plans” and “establishing
standards of conduct, responsibility, and obligation for
fiduciaries of employee benefit plans.”).
A
The communication of claim adjudications to plan
participants and beneficiaries is a “central matter of plan
administration.” Egelhoff v. Egelhoff ex rel. Breiner, 532 U.S.
141, 148 (2001). In Egelhoff, the Supreme Court held that
ERISA preempted a Washington statute that, upon divorce,
automatically revoked the designation of a spouse as the
beneficiary of the proceeds of an employer-sponsored life
insurance policy. Id. at 144–46. The statute directed plan

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administrators to “pay benefits to the beneficiaries chosen by
state law, rather than to those identified in the plan documents.”
Id. at 147. The Court reasoned that the statute “r[an] counter to
ERISA’s commands that a plan shall ‘specify the basis on
which payments are made to and from the plan’ . . . and that
the fiduciary shall administer the plan ‘in accordance with the
documents and instruments governing the plan,’ making
payments to a ‘beneficiary’ who is ‘designated by a participant,
or by the terms of the plan.’” Id. (quoting 29 U.S.C.
§§ 1102(b)(4), 1104(a)(1)(D), 1002(8)). Because the
Washington statute “govern[ed] the payment of benefits, a
central matter of plan administration,” the Court held that it
was preempted. Id. at 148–50.
So too here. Cigna’s explanation of its benefits decision
is “central” to the administration of an ERISA plan. ERISA
requires plans to “provide adequate notice in writing to any
participant or beneficiary whose claim for benefits under the
plan has been denied, setting forth the specific reasons for such
denial, written in a manner calculated to be understood by the
participant.” 29 U.S.C. § 1133(1). Cigna discharges this duty
by issuing the explanation of benefits form. So statements
therein about the reasons for the denial of a claim are
inseparable from Cigna’s duty to provide a written explanation
of claim denials under ERISA. And any state-law claims
challenging the content of such statements would
impermissibly allow state law to regulate matters squarely
within ERISA’s “heartland.” Iola, 700 F.3d at 84; see also
Pilot Life, 481 U.S. at 43, 48 (common-law claims alleging
“improper processing of a claim for benefits under an
employee benefit plan[] undoubtedly meet the criteria for pre-
emption under § 514(a)”). As the District Court observed, “the
fact that Cigna sent the allegedly defamatory EOBs pursuant

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to their obligations under ERISA shows how Dr. Ahn’s claims
relate to ERISA.” Ahn, 2025 WL 830217, at *6.
The United States Court of Appeals for the Fifth Circuit
has adopted similar reasoning. See Mayeaux v. La. Health Serv.
& Indem. Co., 376 F.3d 420 (5th Cir. 2004). In Mayeaux, the
court affirmed an order dismissing a physician’s tort claims
(including defamation) which challenged the insurance
carrier’s “handling, review, and disposition of a request for
coverage.” Id. at 432. As the court explained, allowing medical
practitioners to bring defamation claims when an ERISA plan
administrator decides not to cover a treatment “would
undoubtedly jeopardize the relationships among the traditional
ERISA entities, of which the treating physician is not one.
These are the sort of claims that go to the very heart of the
ERISA administration process.” Id. at 433. As in Mayeaux, Dr.
Ahn sues over the “handling, review, and disposition of a
request for coverage,” id. at 432, and his claim is so intertwined
with his patients’ ERISA plans that it “relates to” those plans,
see Ingersoll-Rand, 498 U.S. at 140 (citation omitted). So
ERISA preempts Dr. Ahn’s defamation per se claim.
Dr. Ahn attempts to distinguish Mayeaux by asserting
that “accusing a medical professional of being ‘unlicensed’
does nothing to establish standards of conduct, responsibility
and obligation for fiduciaries of employee benefit plans.” Ahn
Br. 12. But the relevant inquiry is not whether defaming
providers is central to an administrator’s fiduciary duties. It is
not. The right question to ask is whether communicating
benefits determinations to subscribers and beneficiaries is a
central matter of plan administration. It is.

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B
Preemption applies to this case for a second,
independent reason: Dr. Ahn’s defamation per se claim
“interferes with nationally uniform plan administration.”
Egelhoff, 532 U.S. at 148. “One of the principal goals of
ERISA is to enable employers ‘to establish a uniform
administrative scheme, which provides a set of standard
procedures to guide processing of claims and disbursement of
benefits.’” Id. (quoting Fort Halifax Packing Co. v. Coyne, 482
U.S. 1, 9 (1987)). “Uniformity is impossible, however, if plans
are subject to different legal obligations in different States.” Id.
ERISA provides a civil enforcement “mechanism for
claims by beneficiaries or plan participants to question or
challenge the provision or amount of benefits.” Kollman v.
Hewitt Assoc., LLC, 487 F.3d 139, 150 (3d Cir. 2007). So there
is no need to subject explanation of benefits forms to state tort
claims like defamation. Doing so would be impractical as well.
When determining “the manner” in which claims decisions are
“written,” see 29 U.S.C. § 1133(1), plan administrators and
fiduciaries would have to consider not only ERISA’s
requirements, but also the common law of each state in which
participants and beneficiaries are located or seek services. And
“[r]equiring ERISA administrators to master the relevant laws
of 50 States and contend with litigation would undermine the
congressional goal of ‘minimiz[ing] the administrative and
financial burden[s]’ on plan administrators—burdens
ultimately borne by the beneficiaries.” Gobeille, 577 U.S. at
321 (quoting Egelhoff, 532 U.S. at 149–50). We therefore hold
that ERISA preempts Dr. Ahn’s defamation per se claim
because allowing state defamation laws to regulate the content
of EOBs would undermine uniformity in plan administration.

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C
In his effort to upend the District Court’s decision, Dr.
Ahn offers a mistaken understanding of the governing caselaw.
On his view, a claim that neither seeks benefits under an
ERISA plan nor requires more than a cursory examination of
an ERISA plan is not preempted. See Ahn Br. 12–15 (citing
Plastic Surgery Ctr., P.A. v. Aetna Life Ins. Co., 967 F.3d 218
(3d Cir. 2020)). But Plastic Surgery applied the same standards
we apply today. 967 F.3d at 230–35. He also cites Pascack
Valley Hosp., Inc. v. Loc. 464A UFCW Welfare
Reimbursement Plan, 388 F.3d 393 (3d Cir. 2004), but that
case involved a different ERISA preemption provision than
this one. Id. at 395; see also In re U.S. Healthcare, Inc., 193
F.3d 151, 160 (3d Cir. 1999) (explaining the difference
between complete preemption under ERISA § 502(a) and
express preemption under ERISA § 514(a)). Finally, Dr. Ahn
cites cases supporting the proposition that a provider can bring
a claim under ERISA § 502(a) if he has received an assignment
from a beneficiary. But there has been no such assignment
here. And even had one been made, it would bear only on a
claim brought pursuant to ERISA’s civil remedies provision—
a claim that Dr. Ahn concedes he has not asserted here.
***
ERISA broadly preempts state-law claims. The
explanation of benefits forms at issue in this appeal fall well
within the scope ERISA preemption. We will therefore affirm
the District Court’s summary judgment.
Nicholas A. Vytell

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REPPERT O ATES & V YTELL
Counsel for Appellant
Adam N. Saravay
Scott M. Weingart
M C CARTER & ENGLISH
Counsel for Appellee

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