ERIC L. PATTERSON, on behalf of himself and all others similarly situated v. UNITEDHEALTH GROUP, INC.; UNITED HEALTHCARE SERVICES, INC.; UNITED HEALTHCARE INSURANCE COMPANY; OPTUM, INC.; SWAGELOK COMPANY - Articles

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ERIC L. PATTERSON, on behalf of himself and all others similarly situated v. UNITEDHEALTH GROUP, INC.; UNITED HEALTHCARE SERVICES, INC.; UNITED HEALTHCARE INSURANCE COMPANY; OPTUM, INC.; SWAGELOK COMPANY

Posted by: Azya Thornton on Dec 2, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ON BRIEF: Patrick J. Perotti, Patrick J. Brickman, DWORKEN & BERNSTEIN CO., L.P.A., Painesville, Ohio, Benjamin P. Pfouts, THE HENRY FIRM, Chagrin Falls, Ohio, for Appellant.

Attorneys 2: Wesley E. Stockard, LITTLER MENDELSON, P.C., Atlanta, Georgia, Noah G. Lipschultz, LITTLER MENDELSON, P.C., Minneapolis, Minnesota, for Appellees.

Judge(s): SILER, NALBANDIAN, and READLER, Circuit Judges

Court Appealed: United States District Court for the Northern District of Ohio at Cleveland

READLER, Circuit Judge. Eric Patterson has had a long-running dispute with UnitedHealth Group, his insurer and health plan administrator. In short, Patterson claims that United collected reimbursement for medical expenses paid on Patterson’s behalf even though his health plan gave United no such right. For that reason, Patterson sued United and others under the Employee Retirement Income Security Act of 1974 (ERISA). The district court dismissed those claims, and we largely affirmed the district court on appeal. See Patterson v. United HealthCare Ins. Co., 76 F.4th 487 (6th Cir. 2023). While that appeal was pending, however, Patterson filed an action in state court asserting state law claims against defendants that echoed in substance his federal claims. Defendants removed on the grounds that ERISA completely preempted Patterson’s state law claims and sought dismissal of what it viewed to be a lawsuit duplicative of its federal case. The district court again granted dismissal, and Patterson again appealed. We agree with the district court and affirm.

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