Ryan v. Federal Express Corporation

How courts have described this case

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

• holding that the federal common fund doctrine may not be applied in contravention of a plan’s terms
• holding that employee-participant must reimburse its employer-administrator for recovery from the negligence of a third party under a subrogation clause quite similar to the instant subrogation clause
• explaining that in ERISA cases “straight forward language ... should be given 'its natural meaning” • (citation and internal quotation marks omitted)
• holding that an unambiguous subrogation provision providing for an employee-participant to repay all money received in settlement from a third party does not require applying a federal,common law rule absent a showing that such a rule is necessary to effectuate an ERISA policy
• noting that plan’s terms limited reimbursement to a beneficiary’s net recovery after legal expenses
• refusing to require ERISA plan to pay a proportionate share of attorney fees in recovering subrogation liens as a matter of federal common law

Source: CourtListener parenthetical corpus (CC0).