Johnston v. Cigna Corp.

How later courts describe this case

• party’s property right in cause of action does not vest “until a final, unreviewable judgment has been obtained.”
• Howe I, in which plaintiffs’ contract-type claims that benefits had vested were rejected, does not bar plaintiffs from urging in Howe II that they were entitled to relief on the basis of breach of fiduciary duty or estoppel
• “In both ['Wheeling and Hodges ] ... the rights involved were public rights — as opposed to the private rights asserted here — and a judgment declaring a public right may be annulled by subsequent legislation.”