481 U.S. 41, 56-57, 107 S.Ct. 1549, 95 L.Ed.2d 39 (1987). Congress intended the clause to be broadly-interpreted. Id. However, as the Sixth Circuit has recently explained: preemption and complete preemption are distinguishable concepts. Simply because a claim is preempted by ERISA does not mean it is automatically removable .... “ERISA pre-emption, without more, does not convert a state claim into an action arising under federal law.” A state claim may be preempted by ERISA; however, it is not removable unless it is completely preempted by ERISA. See Wright v. General Motors Corp., 262 F.3d 610, 614 (6th Cir.2001) (quoting Metropolitan Life Ins. Co. v. Taylor, 481 U.S. 58, 64, 107 S.Ct. 1542, 95 L.Ed.2d 55 (1987)); see also Warner v. Ford Motor Co., 46 F.3d 531, 534 (6th Cir.1995) (<HOLDING>). The reasoning behind this is that, generally,
holding that a party did not waive its preemption defense where its answer did not specifically mention preemption but contained a broader defense that was capable of encompassing preemption recognizing limits on the erisa preemption clause holding that there was no federal question removal jurisdiction under the complete preemption exception to the wellpleaded complaint rule holding removal and preemption are distinct concepts erisa preemption does not allow removal unless complete preemption exists holding that removal is proper based on complete preemption only when congress intended the federal cause of action to be exclusive