Joanne Roskey was quoted on a recent decision by a three-judge panel for the Tenth Circuit in a case brought by the Pharmaceutical Care Management Association, finding that federal benefits law preempts parts of an Oklahoma state statute regulating pharmacy benefit managers (PBMs). A major holding from the panel's decision was that the U.S. Supreme Court's 2020 decision in PCMA v. Rutledge didn't change the appellate court's Employee Retirement Income Security Act (ERISA) preemption analysis in Oklahoma. Roskey said that the decision was "a big victory for PBMs, obviously, but also for employers that are seeking uniform administration of their plans across multiple states and multiple circuits. Roskey noted, "[t]his will certainly help them achieve that uniformity goal," and added that the decision "stands out as a counterbalance to the Rutledge decision."