French Mortgage & Bond Co. v. Woodworth

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that a Stay on Letter providing that employees must perform their duties in a “satisfactory manner” to receive benefits did not constitute an ERISA plan
• holding that the \minimal quantum of discretion\ needed to determine whether an employee had been terminated for cause was insufficient to implicate ERISA
• holding that “satisfactory manner” performance' and termination not “for cause” eligibility requirements “failed to rise to the level of ongoing particularized discretion required to transform a simple severance agreement into an ERISA employee benefits plan”
• no ongoing administrative scheme where “[t]he level of discretion, if any, which [the employer] was required to exercise in implementing the agreement was slight”
• “minimal quantum of discretion” involved in for-cause determination was not sufficient to turn a severance agreement into an ERISA plan
• Arizona law did not require consideration of extrinsic evidence where “no language in the contract [was] susceptible to competing interpretations”

Source: CourtListener parenthetical corpus (CC0).