Heideman v. PFL, Inc.

How later courts describe this case

• applying hybrid test to determine whether Texas was teachers' employer under Title VII
• concluding without analysis that state statute for contracts applied
• Having concluded “any retiree’s right to lifetime medical benefits at a particular cost can only be found if it established by contracts,” Circuit determined employer reserved right to alter or terminate plan
• collecting eases where summary judgment was granted on equitable tolling claims in ADEA cases
• concluded without analysis that state statute of limitations for contracts covered the Section 510 claim
• where summary plan description also clearly provided that retiree health insurance could be terminated or modified, these terms of description were controlling
• oral or written communications external to the summary plan description and in non-compliance with section 1022 are inapposite when summary plan description is clear
• booklet that “does not describe ... plan’s terms, specify its benefits or coverage, or define eligibility or limitations” did not amend plan