Varhola v. Doe’s Empirical Analysis
820 F.2d 809 · 1987
Citation profile
52 federal appellate · 5 district · 2 state decisions
How this case has been cited
Cited by 105 later decisions (1 by the Supreme Court) — most recently February 2019 · most notably Mertens v. Hewitt Associates (1993), Davis Farmers Bank Capital Trust Co of Frankfort Kentucky v. Kentucky Finance Cos Retirement Plan (1989)
52 federal appellate · 5 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
Applies 29 U.S.C. § 1001 (§ 2 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1104 (§ 404 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1106 (§ 406 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1109 (§ 409 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1132 (§ 502 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1140 (§ 510 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 186 (§ 302 of the Labor Management Relations Act of 1947 (Taft-Hartley Act))
Relies on Pilot Life Insurance v. Dedeaux · Massachusetts Mutual Life Insurance v. Russell · National Farmers Union Insurance v. Crow Tribe of Indians · Prudential Insurance Co. of America v. United States · Rice v. Norman Williams 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 105 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We hold that the 'arbitrary and capricious' standard of review applies to decisions by [ERISA] plan administrators to deny benefits to particular claimants.”
3 later decisions quote this exact passage · from the majority“Congress had a specific type of problem in mind when it enacted sections 510 and 511: These provisions were added by the Committee in the face of evidence that in some plans a worker’s pension rights or the expectations of those rights were interfered with by the use of economic sanctions or violent reprisals. Although the instances of these occurrences are relatively small in number, the Committee has concluded that safeguards are required to preclude this type of abuse from being carried out and in order to completely secure the rights and expectations brought into being by this landmark reform legislation. S.Rep. No. 93-127, 93d Cong., 2d Sess., reprinted at [1974] U.S.Code Cong. & Admin. News pp. 4838, 4872. The legislative history reveals that the prohibitions [of § 1140] were aimed primarily at preventing unscrupulous employers from discharging or harassing their employees in order to keep them from obtaining vested pension rights. [The opinion here quotes a statement by Senator Hartke on the need to protect workers from being fired or constructively discharged for the purpose of depriving them of pension benefits, and the use of language (“discharge, fine, suspend, expelí [sic], discipline or discriminate”) paralleling that in § 8(a)(3) of the National Labor Relations Act to accomplish such protection.] Thus, it appears Congress designed § 510 primarily to protect the employment relationship that gives rise to an individual’s pension rights.... Of course, an individual”
2 later decisions quote this exact passage · from the majority“Plaintiffs can point to no evidence that Cyclops deliberately discriminated against these employees for the purpose of interfering with their rights under the ... Plan”
2 later decisions 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.