Workers’ Compensation · Primary-source case analysis

Navarro: ERISA Preempted a Section 132a Claim Based on Plan Contributions

By Aneeta Mishra and Timothy Chan

Published May 11, 2026 · Updated October 17, 2026

Decision: Navarro v. A&A Farming, No. GOL 0087934 (WCAB Feb. 13, 2002) (en banc).

Navarro addresses the boundary between California injury-discrimination claims and federally regulated benefit plans. ERISA is the federal Employee Retirement Income Security Act. Here, the challenged benefit was employer funding for a separate group health plan, not medical treatment owed under the workers’ compensation claim.

Coverage ended under plan terms

An injured farmworker lost employer contributions to the group health plan after 90 days off work. The employer had adopted that continuation period before his disability, and it applied to both work-related and other disabilities. The employee argued that section 132a required longer contributions. Navarro, slip opinion, pages 2–4.

The claim depended on administering the ERISA plan

The section 132a theory attacked the employer’s operation of plan eligibility and contribution terms.

ERISA preemption controlled

The claim sought benefits contrary to the employer’s established participation terms. The Board held that enforcing section 132a this way would require changing the ERISA plan’s terms or administration. It did not hold that ERISA defeats every injury-discrimination claim. Navarro, slip opinion, pages 16–19.

The Board resolved the claim on federal grounds

The Board substituted findings against the section 132a claim and did not decide whether the conduct otherwise constituted discrimination.

Key takeaways

• Confirm that the benefit arrangement is an ERISA plan.
• Identify whether liability depends on interpreting plan terms.
• Separate plan-administration disputes from independent retaliatory acts.
• Preserve federal and state procedural options.