NEW YORK - A New York federal judge on March 21 denied a plaintiff's motion to remand her denial of health care benefits case to state court, holding that the Employee Retirement Income Security Act preempted her claims (S.M. v. Oxford Health Plans (NY) Inc., et al., No. 12-4679, S.D. N.Y.; 2013 U.S. Dist. LEXIS 40408).