The U.S. District Court for the Northern District of California has found, in In Re Anthem, Inc. Data Breach Litigation, that the Employee Retirement Income Security Act (ERISA) preempts state law breach of contract and unjust enrichment claims brought against Anthem after its data breach one year ago.  The court therefore held that the case was properly removed to federal court on the basis of federal question jurisdiction under ERISA.  This decision, if upheld on appeal, will be helpful to defendants in breach cases involving ERISA-regulated benefits plans, allowing them to avoid more plaintiff-friendly state courts.