Complete preemption

“The Supreme Court has held that a state cause of action is ‘really’ a federal cause of action which may be removed to federal court if the "federal cause of action completely preempts . . . the state cause of action.’” “This principle is ‘known as the complete preemption doctrine, and it is ‘a distinct concept from ordinary preemption.’” “[T]he complete preemption doctrine applies only if ‘the statute relied upon by the defendant as preemptive contains civil enforcement provisions within the scope of which the plaintiff's state claim falls.’”