Judge Thomas Hardiman, of the U.S. Court of Appeals for the Third Circuit, speaking during a panel discussion at the Federalist Society’s 2018 National Lawyers Convention, held at The Mayflower Hotel in Washington, D.C., on Friday, November 16, 2018. In an issue of first impression, a federal appellate court has ruled that the Employee Retirement Income Security Act of 1974 preempts medical providers’ claims for defamation connected to allegedly false benefits information given to policyholders.