York v. First Presbyterian Church

How later courts describe this case

• holding that state common law claims for breach of contract and implied contract, promissory estoppel, estoppel by conduct, and fraud and deceit are preempted under ERISA
• rejecting rule that exposure to asbestos creates right to payment for F.E.L.A. tort cause of action
• finding plan administrator acted arbitrarily and capriciously by attempting to impose additional conditions of eligibility above and beyond those required by the terms of the plan
• absent a defendant’s bad-faith failure to comply with ERISA’s reporting requirements, employees ordinarily have no substantive remedy under the Act
• in determining whether benefits were improperly denied under ERISA, "this court, like the trial court, reviews another decisionmaker: the welfare benefit plan administrator."
• common law claims of breach of contract implied in fact, promissory estoppel, estoppel by conduct, fraud, and breach of contract preempted
• claimant who suffers because of a fiduciary’s failure to comply with procedural requirements is ordinarily entitled to no substantive remedy
• railroad workers’ "future F.E.L.A. causes of action were not dischargeable claims under section 77” of the former bankruptcy act