High v. E-Systems Inc.’s Empirical Analysis
459 F.3d 573 · 2006
Citation profile
13 federal appellate · 1 district · 1 state decisions
How this case has been cited
Cited by 47 later decisions — most recently June 2023 · most notably Holland v. International Paper Co. Retirement Plan (2009), Wade v. Hewlett-Packard Development Co. LP Short Term Disability Plan (2007)
13 federal appellate · 1 district · 1 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 LOCKHEED CORP. Et Al. v. SPINK · Sprague v. General Motors Corp. · Hozier v. Midwest Fasteners, Inc. · Wildbur v. Arco Chemical Co. · Barnett v. Aetna Life Insurance Co.
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 47 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We have not specifically defined this term, rather we rely on caselaw to establish its parameters. In Rosen v. Hotel and Restaurant Employees and Bartenders Union, 637 F.2d 592 (3d Cir.1981), we found that extraordinary circumstances existed when the trustee of a pension fund advised Rosen that his pension was in jeopardy due to his employer’s failure to make payments to the fund, allowed Rosen to write out a check for the remainder of the employer’s debt, and deposited the check. Id. at 598 . We held that the trustee was then estopped from asserting that Rosen’s payment did not entitle him to his pension. Id. By contrast, in Gridley v. Cleveland Pneumatic Co., 924 F.2d 1310 (3d Cir.1991), Gridley, while continually and totally disabled in the hospital, increased his life insurance coverage under a plan that specifically required active, full-time status for such an increase. Although the employer deducted additional amounts from his salary to cover the increase, we found that extraordinary circumstances did not exist when the insurance carrier refused the additional amount. Id. at 1319 (citing Hozier v. Midwest Fasteners Inc., 908 F.2d 1155 , 1165 n. 10 (3d Cir.1990)).... [In this case,] we have another hospital misrepresenting the type of coverage for which recipients could enroll. Capital Health compounded its error by reassuring Mrs. Curcio that she was covered in the amount of $400,000 after the accidental death of her husband.... Although it was not in Capital Health’s ”
1 later decision quote this exact passage · from the majority“Only when the plan terms remain ambiguous after applying ordinary principles of contract interpretation does this court apply the rule of contra proferentum and construe the terms strictly in favor of the insured. [Plaintiff] High's case, however, does not warrant the application of this rule; the language of the E-Systems Plan is [not] ambiguous and, as E-Systems suggests, by giving MetLife [the Plan Administrator] complete discretion to interpret the plans, if there had been an ambiguity, Met-Life was empowered to resolve it, exercising “interpretive discretion.””
1 later decision quote this exact passage · from the majority“When, as here, the language of the plan grants discretion to an administrator to interpret the plan and determine eligibility for benefits, a court will reverse an administrator's decision only for abuse of discretion.”
1 later decision quote this exact passage · from the majority
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.