HOLDINGS: [1]-Because a medical provider’s causes of action for breach of implied contract under Civ. Code, §§ 1619, 1621, intentional misrepresentation, and quantum meruit brought against a plan governed by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. § 1001 et seq., sought to recover unpaid benefits and related to claims handling and payment, conflict preemption under ERISA § 514 (29 U.S.C. § 1144) barred these causes of action; [2]-Although the provider’s causes of action for unfair competition under Bus. & Prof. Code, § 17200 et seq., and intentional interference with prospective economic relations were not preempted because they alleged intentional acts beyond claims evaluation and processing, the plan was entitled to summary judgment because there was no evidence to show that the plan had made assurances of payment while intending to withhold payment.
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Outcome
Judgment affirmed.