( August 26, 2026, 8:23 AM EDT) -- PASADENA, Calif. — Ruling that the Employee Retirement Income Security Act preempts a promissory estoppel claim but not a negligent misrepresentation claim, the Ninth Circuit U.S. Court of Appeals revived the latter state law claim in a reimbursement dispute that concerns surgery done by an out-of-network provider for an individual who had an employer-sponsored health plan....