Tony Shelley, quoted extensively in an article about recent court decisions concerning the Employee Retirement Income Security Act (ERISA), states that the two trial court decisions are significant developments in the ERISA preemption arena because "they are the first two decisions to address the effort by the National Association of Insurance Commissioners to change the standard of review in ERISA benefits cases." Shelley further states that the two trial courts were "too quick" to rely on the Rush Prudential decision and that health insurers and employee benefit plans "have a good argument" that the insurance commissioners are improperly attempting to alter the remedy available to ERISA beneficiaries.