Geiger v. New York Life Insurance Co

How later courts describe this case

• declining to decide--in light of its finding that any error was harmless--whether the Confrontation Clause entitles defendant to impeach victim's own statements about her sexual history
• "This Court finds that the Plan's reimbursement language is unambiguous, and . . . overrides the make whole rule."
• “A party cannot invoke Rule 59(e) to raise arguments or evidence that could and should have been presented during the summary judgment process.”
• “Because .... the make whole rule is just,a principle of interpretation, it can be overridden by clear language in the plan.”