Skillin v. Rady Children’s Hosp. of San Diego, 2017 WL 6029754 (Cal. Ct. App. 2017)

David Skillin brought a Private Attorneys General Act lawsuit against his former employer, Rady Children’s Hospital of San Diego, based upon allegedly unauthorized payroll deductions that the hospital made from his wages, resulting in higher than desired contributions to his retirement plan. The trial court granted summary judgment in favor of the hospital, and the Court of Appeal affirmed, holding that Skillin’s claims were preempted by the Employee Retirement Income Security Act of 1974 (“ERISA”).