Rutledge v. Pharmaceutical Care Management Assn.
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Rutledge v. Pharmaceutical Care Management Assn. and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Rutledge v. Pharmaceutical Care Management Assn..
The Supreme Court addressed whether Arkansas' Act 900, which regulates pharmacy benefit managers (PBMs), is pre-empted by the Employee Retirement Income Security Act of 1974 (ERISA). The Court found that Act 900 does not have an impermissible connection with or reference to ERISA plans, as it merely regulates reimbursement rates without dictating plan choices. The decision reversed the Eighth Circuit's ruling, which had affirmed ERISA pre-emption.
Holding
The single most important “bottom line” of what the Court decided in Rutledge v. Pharmaceutical Care Management Assn..
The Court held that Arkansas' Act 900 is not pre-empted by ERISA.
Constitutional Concepts
These are the Constitution-related themes that appear in Rutledge v. Pharmaceutical Care Management Assn.. Click a concept to see other cases that involve the same idea.
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Why Preemption is relevant to Rutledge v. Pharmaceutical Care Management Assn.
The central issue in the case is whether Arkansas' Act 900 is pre-empted by ERISA, which is a question of federal law overriding state law.
Syllabus excerpt (verbatim)Held: Arkansas' Act 900 is not pre-empted by ERISA. Pp. 86–92.
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Why State–Federal Power is relevant to Rutledge v. Pharmaceutical Care Management Assn.
The case involves the allocation of authority between state and federal governments, specifically whether a state law can regulate PBMs without conflicting with federal ERISA regulations.
Syllabus excerpt (verbatim)Act 900 affects plans only insofar as PBMs may pass along higher pharmacy rates to plans with which they contract, and Act 900 regulates PBMs whether or not the plans they service fall within ERISA's coverage.
Key Quotes
Short excerpts from the syllabus in Rutledge v. Pharmaceutical Care Management Assn. that support the summary and concepts above.
Arkansas' Act 900 is not pre-empted by ERISA.
Act 900 is merely a form of cost regulation that does not dictate plan choices.
ERISA plans are therefore also not essential to Act 900's operation.
