Forever indebted to Judge Young, bard of #ERISA, for his #preemption dirge in Andrews-Clarke, 984 F. Supp. 49 (D. Mass. 1997). It's a masterful lamentation on entwined tragedies: Mr. Clarke's death and ERISA preemption's endurance.
An #ERISA plan covered Mr. Clarke,
with pre-utilization review.
"As a consequence of their failure to pre-approve" his admission to inpatient rehab
"Clarke never received the treatment
he so desperately required,
suffered horribly, and
ultimately died needlessly at age 41."
