On June 28, 2010, the U.S. Supreme Court declined to review an appeals court decision that upheld a San Francisco ordinance that requires companies doing business in the city to provide health care coverage to all employees. The Court’s order was a setback for WLF, which filed a brief urging the Court to grant review. WLF argued that such ordinances are preempted by federal law, which comprehensively regulates employer health care plans through the Employee Retirement Income Security Act (ERISA). The San Francisco ordinance imposes obligations in addition to those adopted in connection with the health care legislation recently passed by Congress. It is part of a growing trend among state and local governments to attempt to regulate health care plans. Such regulations mandate benefit levels for employees at private companies through so-called “pay-or-play” laws: either “play” by providing health care or “pay” into a city fund to cover the costs of city-provided health care.