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Stephens v. Harbor Club Inc.

ERISA did not pre-empt plaintiff's claim that her employer fraudulently misrepresented her entitlement to workers' compensation benefits, because that claim was not related to any ERISA benefits program.

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Glenda Stephens appeals from the trial court’s dismissal of her complaint against Harbor Club for lack of subject matter jurisdiction. Because Stephens’s claims for damages arising from Harbor Club’s alleged fraud in preventing her from filing a worker’s compensation claim do not relate to any ERISA governed benefit plan, the trial court erred in concluding that it did not have subject matter jurisdiction over the complaint.

This case arose when Stephens, who worked as a waitress for Harbor Club, ruptured a disc in her neck while lifting a tray of dishes. After the injury, Stephens’s supervisor told her that this “would not be a worker’s compensation claim and would not be reported to worker’s compensation by Harbor Club” and would instead be handled by medical insurance.

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