1、1 See Julia Contreras and Orly Lobel, Wal-Martization and the Fair Share Health Care Acts, 19St. Thomas L. Rev. 105, 108 (2006) (citing statistics from the U.S. Census Bureau showing thatthe number of individuals without health insurance increased from 41.0 million in 2000 to 45.8million in 2004). S
2、ee also Kaiser Fam. Found. & Health Research & Educ. Trust, EmployerHealth Benefits: 2006 Annual Survey 4 (2006), available at http:/www.kff.org/insurance/7527/upload/7527.pdf (“Sixty-one percent of firms offer health benefits to at least some of theiremployees . Since 2000, the percentage of firms
3、offering health benefits has fallen from 69%.”).2 See Amy Vandenbroucke, Fair Share Laws, 9 DePaul J. Health Care L. 1343, 1346 (2006).3 Id.Order Code RS22648April 24, 2007Required Healthcare Contributions, FairShare Legislation, and RILA v. FielderJon O. ShimabukuroLegislative AttorneyAmerican Law
4、DivisionSummaryIn RILA v. Fielder, the U.S. Court of Appeals for the Fourth Circuit affirmed thedecision of a federal district court that found Marylands Fair Share Health Care FundAct (“Fair Share Act”) to be preempted by the Employee Retirement Income SecurityAct (“ERISA”), a federal statute that
