Heideman v. PFL, Inc.

applying hybrid test to determine whether Texas was teachers' employer under Title VII | concluding without analysis that state statute for contracts applied | applying hybrid test to determine whether Texas was teachers’ employer under Title VII | 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 | “any retiree's right to lifetime benefits at a particular cost can only be found if it is established by contract under the terms of the ERISA-gov-erned benefit plan document” | federal common law claim of estoppel only available where plan provision ambiguous and representations are made to employee involving oral interpretation of ambiguous provision | where summary plan description also clearly provided that retiree health insurance could be terminated or modified, these terms of description were controlling | "Congress expressly prohibited informal written amendments of ERISA plans.”