York v. First Presbyterian Church

holding that state common law claims for breach of contract and implied contract, promissory estoppel, estoppel by conduct, and fraud and deceit are preempted under ERISA | holding that state common law claims for breach of contract and implied contract, promissory estoppel, estoppel by conduct, and fraud and deceit are preempted under ERISA | rejecting rule that exposure to asbestos creates right to payment for F.E.L.A. tort cause of action | finding plan administrator acted arbitrarily and capriciously by attempting to impose additional conditions of eligibility above and beyond those required by the terms of the plan | absent a defendant’s bad-faith failure to comply with ERISA’s reporting requirements, employees ordinarily have no substantive remedy under the Act | in determining whether benefits were improperly denied under ERISA, "this court, like the trial court, reviews another decisionmaker: the welfare benefit plan administrator." | in determining whether benefits were improperly denied under ERISA, “this court, like the trial court, reviews another decisionmaker: the welfare benefit plan administrator.” | common law claims of breach of contract implied in fact, promissory estoppel, estoppel by conduct, fraud, and breach of contract preempted | claimant who suffers because of a fiduciary’s failure to comply with procedural requirements is ordinarily entitled to no substantive remedy | railroad workers’ "future F.E.L.A. causes of action were not dischargeable claims under section 77” of the former bankruptcy act | “a person may hold a ‘contingent’ claim and thereby be a ‘creditor’ within the meaning of the Bankruptcy Act” | absent a defendant’s bad faith for failure to comply with ERISA’s, reporting requirements, employees ordinarily have no substantive remedy under the Act | where plan provides severance pay to employees whose jobs were “eliminated,” the subsequent reinstatement of those positions by successor corporation is irrelevant to the employees’ entitlement to the severance benefits | damages not recoverable for future risk of cancer due to exposure to asbestos | Del Monte kept the Plan document confidential; the policy was subject to no claims procedure; there was no summary plan description; and there was no provision to inform participants in writing of anything | “Once established, ERISA operates to protect an employee’s interest in the welfare benefit program regardless of whether the employer complies with the administrative and reporting requirements detailed under ERISA.” | no independent constitutional or statutory right to jury trial in ERISA action | state common-law claims for breach of contract, estoppel, fraud, and deceit | possible existence of sub-clinical asbestos-related harm insufficient to sustain tort claim | reiterated in Nevill v. Shell Oil Co., 835 F.2d 209, 213 (9th Cir.1987) | claims based on breach of contract and fraud and deceit | state common-law claims for breach of contract, estoppel, fraud, and deceit