U.S. at 47-48, 107 S.Ct. 1549 (finding that the plaintiffs claims, each based on alleged improper processing of a claim for benefits under a qualified ERISA plan, “undoubtedly” met the criteria for preemption under § 514(a), despite the fact the state laws at issue did not expressly reference ERISA plans); Kuhl, 999 F.2d at 302 (having no difficulty concluding the plaintiffs’ claims, all arising from the administration of benefits under a qualified ERISA plan were preempted by ERISA); see also Parkman v. Prudential Ins. Co. of Am., 439 F.3d 767, 771-72 (8th Cir.2006) (“ERISA preempts ‘state common law tort and contract actions asserting improper processing of a claim for benefits’ under an ERISA plan.”) (quoting Pilot Life Ins. Co.); Fink v. Dakotacare, 324 F.3d 685, 689 (8th Cir.2003) (<HOLDING>); Howard v. Coventry Health Care, of Iowa,
holding that state common law causes of action asserting improper processing of a claim for benefits under an employee benefit plan are removable to federal court holding that erisa preempted state law claim brought by employer against insurance company for wrongful claims processing holding that state law causes of action arising from improper processing of a claim for benefits are preempted holding negligent misrepresentation claim was not preempted because it neither sought benefits under plan nor alleged improper processing of benefits holding erisa preempts state contract and tort actions based on improper processing of claims for benefits