care expenses by 2011 through measures such as attracting a younger, implicitly healthier work force by offering education benefits. The memo also suggested giving sedentary Walmart staffers, such as cashiers, more physically demanding tasks, such as "cart-gathering", and eliminating full-time positions in favor of hiring part-time employees who would be ineligible for the more expensive health insurance and several policy proposals which may violate the Americans with Disabilities Act of 1990. The memo also accused Walmart's lower paid employees of abusing emergency room visits, "possibly due to their prior experience with programs such as Medicaid", whereas such visits may actually be due to the reduced ability of uninsured or underinsured people to make timely appointments to see a regular physician. On January 12, 2006, the Maryland legislature enacted a law requiring that all corporations with more than 10,000 employees in the state spend at least eight percent of their payroll on employee benefits, or pay into a state fund for the uninsured. Walmart, with about 17,000 employees in Maryland, was the only known company to not meet this requirement before the bill passed. On July 7, 2006, the Maryland law was overturned in federal court by a United States District judge who held that a federal law, the Employee Retirement Income Security Act (ERISA), preempted the Maryland law. The judge said the law would "hurt Walmart by imposing the administrative burden of tracking benefits in Maryland differently than in other states." On April 17, 2006, Walmart announced it was making a health care plan available to part-time workers after one year of service, instead of the prior two-year requirement. By January 2007, the number of workers enrolled in the company's health care plans increased by 8%, which Walmart attributed to the introduction of less expensive insurance policies. However, even with this increase, less than half of Walmart's employees, or 47.4%, received health insurance through the company, with 10%, or 130,000, receiving no coverage at all. In March 2008, Walmart sued a former Walmart employee, Deborah Shank, to recover the money it spent for her health care after she was brain-damaged, restricted to a wheelchair, and nursing home-bound after her minivan was hit by a truck. Walmart sued the former employee for $470,000 after she received a settlement from the accident, citing that company policy forbids employees from receiving coverage if they also win a settlement in a lawsuit. After a