Franklin v. Main

How later courts describe this case

• holding that an oral interpretation of an ambiguous plan provision will be given effect
• stating that contribution right is extinguishable and bar orders appropriate in securities class action
• distinguishing Nachwalter as being limited to modifications, but otherwise indicating, without discussion, that Nachwalter would apply to this welfare benefits case
• noting the “rule that estoppel may not be invoked to enlarge or extend the coverage specified in a contract”
• allowing application of federal common law estoppel to representations about COBRA rights statutorily included in all ERISA-covered plans
• allowing application of estoppel principles where interpreting ambiguities in benefit plans
• ADEA government employee plaintiff filed his suit in court before administrative appeal was decided by the EEOC
• “Federal courts possess the authority, however, to develop a body of federal common law to govern issues in ERISA actions not covered by the act itself.”