NEW ORLEANS - The Employee Retirement Income Security Act preempts state law claims by a beneficiary of a life insurance policy, which was converted to an individual policy, on her allegations that the insurer failed to pay the amount owed under the policy and the doctrines of estoppel and waiver did not apply, a federal judge in Louisiana ruled May 2 (Sankey v. Metropolitan Life Ins. Co. et al., No. 12-1135, E.D. La.; 2013 U.S. Dist. LEXIS 62964).