CINCINNATI - Pension plan participants' state law claim for tortious interference with a contract is not completely preempted under the Employee Retirement Income Security Act because the participants alleged a violation of a duty that was independent of the ERISA plan, the Sixth Circuit U.S. Court of Appeals ruled May 10 in ordering remand of the case to state court (Lee Gardner, et al. v. Heartland Industrial Partners, LP, et al., No. 11-2377, 6th Cir.; 2013 U.S. App. LEXIS 9470).