1. Duking It Out: Beating the Complete Preemption of ERISA Under Dukes v;Natalie Zellner;U.S. Healthcare, Inc., 14 Ga. St. U. L. Rev,1998
2. The Circuitous Journey To The Patients' Bill of Rights: Winners and Losers, 65 Alb;Sharon Reece;L. Rev,2001
3. n25 Although many complain about the complexities of managed care, and are wistful about the simplicity of the fee-for-service approach, more Americans than ever get health care. See Andy Miller, Managed Care Savings Noted;Atlanta J. & Const,1997
4. Total enrollment in MCOs during 2001 was estimated at 178 million. Centers for Medicare and Medicaid Services, Managed Care Fact Sheets, National Managed Care Enrollment;n26 In 1980, only four percent of Americans were enrolled in HMO's,2000
5. See generally, Wendy Silver, Note, The Inadequacy of State Legislative Responses to ERISA Preemption of Managed Care Liability;See Ardyth;When HMO Patients Can't Get No Satisfaction, 4 DePaul J. Health Care L,1960