In cases akin to the instant case, where the State Treasurer has sued a prisoner to collect costs of incarceration under SCFRA, an asserted defense of ERISA preemption has not been deemed sufficient to justify removal to federal court. See, e.g., State Treasurer v. Wilson, No. 07-15025, 2008 WL 506544 (E.D. Mich. February 22, 2008); State Treasurer v. Wilson, No. 2:09-CV-241, 2010 WL 1949569 (W.D. Mich. May 14, 2010). IV. Conclusion