Cite as: 520 U. S. 806 (1997)
Opinion of the Court
The Court of Appeals for the Second Circuit reversed. It distinguished cases in which we had found that certain "laws of general application" were not pre-empted by ERISA,6 explaining that the HFA "targets only the health care industry," which is, "by definition, the realm where ERISA welfare plans must operate," NYSA-ILA Medical and Clinical Services Fund v. Axelrod, M. D., 27 F. 3d 823, 827 (1994). The court reasoned that because the HFA "operates as an immediate tax on payments and contributions which were intended to pay for participants' medical benefits," it directly affects "the very operations and functions that make the Fund what it is, a provider of medical, surgical, and hospital
State." Respondents contended that the statute did not apply because the New York courts do not provide the "plain" remedy required to bar federal jurisdiction. The District Court appears to have agreed with respondents, see App. to Pet. for Cert. 19a, but when it ultimately granted summary judgment and dismissed the complaint, it did not squarely decide the question, id., at 19a, 22a-23a. The Court of Appeals did not address the Tax Injunction Act in either of its two opinions in this case and there is no suggestion anywhere in the papers that the State raised the issue before that court. The Second Circuit had previously held, however, that the Tax Injunction Act is not a bar to actions such as this. See Travelers Ins. Co. v. Cuomo, 14 F. 3d 708, 713-714 (1993), rev'd on other grounds, New York State Conference of Blue Cross & Blue Shield Plans v. Travelers Ins. Co., 514 U. S. 645 (1995). In Travelers, we noted, but did not reexamine, that conclusion. See id., at 652-653, n. 4. In the case at bar, the Court of Appeals presumably was satisfied that its jurisdiction was secure for the reasons given in Travelers. Before this Court, no party in either Travelers or the current case has mentioned the Tax Injunction Act or questioned the Court of Appeals' conclusion that a "plain" remedy is unavailable in the New York courts. Given our settled practice of according respect to the courts of appeals' greater familiarity with issues of state law, cf. Bishop v. Wood, 426 U. S. 341, 346-347, and n. 10 (1976), and the State's active participation in nearly four years of federal litigation with no complaint about federal jurisdiction, it is appropriate for us to presume that the Court of Appeals correctly determined that, under these circumstances, New York courts did not provide a "plain" remedy barring federal consideration of the state tax.
6 See, e. g., Mackey, 486 U. S., at 838 (generally applicable garnishment law not pre-empted); Fort Halifax Packing Co., 482 U. S., at 19 (state law requiring one-time severance payment not pre-empted).
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