plan and (2) require insurers to provide certain procedural protections to insureds (even if the insurance is provided as part of an ERISA-covered employee benefit plan). Aetna Health struck down the state statute at issue because “any state-law cause of action that duplicates, supplements, or supplants the ERISA civil enforcement remedy conflicts with the clear congressional intent to make the ERISA remedy exclusive and is therefore pre-empted.” Aetna Health, 542 U.S. at -, 124 S.Ct. at 2495. The Su preme Court has consistently struck down state laws that create claims for relief against ERISA-covered employee benefit plans, even if those state laws also regulate insurance. See, e.g., Ingersoll-Rand Co. v. McClendon, 498 U.S. 133, 135, 145, 111 S.Ct. 478, 112 L.Ed.2d 474 (1990) (<HOLDING>); Pilot Life, 481 U.S. at 57, 107 S.Ct. 1549
holding that a wrongful discharge claim based on violation of a state public policy is not preempted because it is a nonnegotiable independent statelaw right recognizing cause of action for wrongful discharge holding that the test for preclusion of a common law wrongful discharge claim is disjunctive holding that an employees claim for relief for wrongful discharge based on state common law was preempted by  1132a recognizing common law tort claim for wrongful discharge in violation of ohio public policy based upon statutory and judicial sources