Workers’ Compensation · Primary-source case analysis

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

By Aneeta Mishra and Timothy Chan

Published September 13, 2026

Navarro addresses the boundary between California injury-discrimination claims and federally regulated benefit plans.

Coverage ended under plan terms

An injured farmworker lost employer contributions to a group health plan after he stopped active work.

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

Because the claim related directly to an established ERISA employee-welfare plan, federal law preempted the state claim.

The WCAB rescinded the contrary finding

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.