Betancourt

We granted review to determine whether the federal Employee Retirement Income Security Act of 1974 (ERISA) ( 29 U.S.C. § 1001 et seq.) preempts a mechanic’s lien action (Civ. Code, § 3110) brought by laborers to recover unpaid contributions to their employee benefit plans. ERISA preempts state laws that “relate to” employee benefit plans. ( 29 U.S.C. § 1144 (a).) In 1991, we held that ERISA preempted a similar mechanic’s lien statute (§ 3111) that “single[d] out ERISA plans for special treatment” and, thus, related to employee benefit plans. (Carpenters So. Cal. Admin. Corp. v. El Capitan Development Co. (1991) 53 Cal.3d 1041, 1049 [ 282 Cal.Rptr. 277 , 811 P.2d 296 ] (El Capitan).) Because section 3110 is a law of general applicability and does not “relate to” ERISA plans ( 29 U.S.C. § 1144 (a)), we conclude that ERISA does not preempt plaintiffs’ action.

Factual and Procedural Background

The facts are largely taken from the Court of Appeal’s opinion.

R. Betancourt and other employees (laborers) are union members who worked for R. P. Richards, a subcontractor of Trabucco & Associates. R. P. Richards employed laborers pursuant to a collective bargaining agreement…