Bad faith
The ruling was informed largely by ERISA judicial precedent (judge-made, or common law), as established early in ERISA's judicial history, especially "Pilot Life v. Dedeaux," 1987. In the latter case, the language of ERISA and other evidence of congressional intent, including ERISA's legislative history; the expansive interpretation of ERISA's preemption clause (i.e. ERISA supersedes state laws that "relate to" private employer-sponsored benefit plans, with no specific guidance in the wording of the clause as to how Congress intended "relate to" to be interpreted); coupled with ERISA's enforcement scheme, which includes Equitable Remedies but not Legal Remedies, led to the conclusion that state law Causes of action for legal remedies under Mississippi common law for Bad faith denial of insurance claims, including compensatory and punitive damages, were not allowed by ERISA.