Franklin v. Main

holding that an oral interpretation of an ambiguous plan provision will be given effect | holding that an oral interpretation of an ambiguous plan provision will be given effect | holding that an oral interpretation of an ambiguous plan provision will be given effect | holding that an oral interpretation of an ambiguous plan provision will be given effect | 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 | stating that contribution right is extinguishable and bar orders appropriate in securities class action | 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.” | oral representations could be used to explain an ambiguous clause in an ERISA employee welfare benefits plan. | de novo review appropriate where Aetna did not have discretion in administering the plan | ERISA-estoppel claim permitted to proceed where plan held ambiguous | applying estoppel to medical benefits plan