Elmore’s Empirical Analysis
Citation profile
1 federal appellate · 9 district · 2 state decisions
How this case has been cited
Cited by 54 later decisions — most recently October 2023 · most notably Rodger Cripe (2001), 958 F. Supp. 869 - Mason Tenders District Council Pension Fund v. Messera (1997)
1 federal appellate · 9 district · 2 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Firestone Tire and Rubber Company v. Bruch · Singleton v. Wulff · Shaw v. Delta Air Lines, Inc. · Massachusetts Mutual Life Insurance v. Russell · Hormel v. Helvering
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 54 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Under ERISA, plan fiduciaries must provide benefits only “in accordance with the documents and instruments governing” the employee pension benefit plan. 29 U.S.C.A. § 1104 (a)(1)(D) (emphasis added); see also Dzinglski v. Weirton Steel Corp., 875 F.2d 1075, 1080 (4th Cir.) (“To adhere to the plan is not a breach of fiduciary duty.”), cert. denied, 493 U.S. 919 , 110 S.Ct. 281 , 107 L.Ed.2d 261 (1989). It is undisputed that the surplus representation was not incorporated into the written terms of the 1983 ESOP plan documents adopted by Defendants on April 2, 1984. Instead, the actual plan documents only mandated that Cone Mills provide benefits under the 10%/10%/1% formula. Nonetheless, the district court found that an employer representation not contained in the formal plan documents could become a part of the plan if the promise to provide benefits was contained in a written, formal, authorized, and ratified statement sent by the employer’s CEO to all of the employer’s salaried employees. In reaching its conclusion, the district court applied the inverse logic of our holding in Pizlo v. Bethlehem Steel Corp., 884 F.2d 116 (4th Cir.1989). In Pizlo , we held that a plaintiff does not have a cause of action for benefits under ERISA when such benefits were promised in informal and unauthorized amendments to the benefit plan. Id. at 120 . We did not state, however, that employees are entitled to recover benefits under any written statement made by a company official, even if auth”
1 later decision quote this exact passage · from the majority“informal plan may exist independent of, and in addition to, a formal plan as long as the informal plan meets”
1 later decision quote this exact passage · from the majoritye.g. Charles Deboard
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.