exempt[s] any plan established or maintained ‘by the government of any State or political subdivision thereof for its employees.” (emphasis added)). These findings and application of the governmental plan exclusion would be unnecessary if, as the State contends, governmental plans do not fall under the broader definition of “employee welfare benefit plan” in the first instance. In fact, courts and litigants typically take for granted that governmental plans qualify as employee' benefit plans within the meaning of ERISA — skipping instead to the more difficult question of whether the benefit plan in-question qualifies for exclusion under § 1003(b)(1). See, e.g., Komanicky v. Teachers Ins. & Annuity Ass’n, 230 F.3d 1358, 2000 WL 1290357, at *2 (6th Cir.2000) (unpublished table decision) (<HOLDING>); Eschleman v. UnitedHealth Grp., Inc., No.
holding that employee benefit plan sponsored by two participating employers  cook county and the cook county forest preserve district  qualified for governmental plan exclusion holding that disability plan established by state university for benefit of employees qualified for governmental plan exclusion holding that county governments healthcare plan qualified for governmental plan exclusion holding that where a governmental entity purchases a benefit plan on behalf of government employees and dele gates the administration to a private insurer the plan is a government plan exempt from erisa holding that healthcare plan established by the state of vermont for eligible employees qualified for governmental plan exclusion