Tony Shelley writes that the Federal Employees Health Benefits Act (FEHBA) preempts a plan administrator’s state law claim for reimbursement from an enrollee under the plan’s subrogation provision, the U.S. Court of Appeals for the Seventh Circuit ruled Jan. 24 (Blue Cross and Blue Shield of Illinois v. Cruz, 7th Cir., No. 03-4170, 1/24/05).