SEATTLE - The Employee Retirement Income Security Act completely preempts a claim that an insurer violated the Washington Insurance Fair Conduct Act by denying a claim for benefits under an employer-sponsored life insurance plan, a federal judge in Washington ruled Aug. 23 (Alan Chan, et al. v. Prudential Insurance Company of America, No. 12-524, W.D. Wash.; 2013 U.S. Dist. LEXIS 120428).