The Sunbeam-Oster Company, Inc. Group Benefits Plan for Salaried and Non-Bargaining Hourly Employees v. Leonard Whitehurst, Jr.

How courts have described this case

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

• explaining that the plan summary need not “expressly address every conceivable factual variation of recovery”
• noting that in some circumstances, the SPD may be the only 10 plan document
• observing that sub-rogation was properly disclosed to claimant via the SPD
• stating, in dicta, that even in absence of standard subrogation language in the SPD, it doubted it would adopt Make Whole doctrine as a default rule
• “Federal courts have consistently applied [Firestone Tire and Rubber Co. v. Bruch, 489 U.S. 101 (1989
• “Federal courts have consistently applied Firestone’s deference principles to actions concerning benefit determinations brought not only by participants but also by ERISA plans and, in particular, claims involving ERISA plans’ assertions of purported reimbursement and subrogation rights.”

Source: CourtListener parenthetical corpus (CC0).