Doris Russell v. Massachusetts Mutual Life Insurance Company, Celia Stevenson

Doris Russell sued in California Superior Court to recover damages allegedly resulting from the termination of her employment with Massachusetts Mutual Life Insurance Company (Mutual). She also sought damages allegedly resulting from the improper processing of her claim for employee disability benefits. Russell’s complaint asserted several causes of action based on Mutual’s handling of her disability benefits, including claims for breach of the statutory covenant of good faith and fair dealing under Cabins. Code § 790.03(h)(5) (West Supp.1982), and breach of fiduciary duty. Russell also asserted a claim for breach of her employment contract and of the implied contractual covenant of good faith and fair dealing. Finally, she alleged the intentional and negligent infliction of emotional distress in connection with both the handling of her disability benefits and the termination of her employment. The relief sought by Russell included both compensatory and punitive damages.

Mutual removed the action to federal district court, alleging that Russell’s disability causes of action relating to her benefits were preempted by the Employee Retirement Income Security Act of 1974 (ERISA), 29…