Franklin v. Pitney Bowes, Inc.’s Empirical Analysis
919 F.2d 45 · 1990
Citation profile
4 federal appellate · 1 district ·
Relationships
Applies 29 U.S.C. § 1021 (§ 101 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1132 (§ 502 of the Employee Retirement Income Security Act of 1974)
Relies on Hensley v. Eckerhart · Firestone Tire and Rubber Company v. Bruch · Don Ray Smith v. Cmta-Iam Pension Trust · Blakeman v. Mead Containers
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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Plaintiffs also contend that the company should be estopped from claiming that they were not entitled to severance pay or, at least, that terms of the plan should be interpreted strictly against the company because it failed to set out the plan in writing and provide its employees with summaries of the plan as required by ERISA____ While a court evaluating the conduct of a plan administrator under the de novo standard will take into account instances of this nature where an administrator fails to follow one of ERISA’s procedural requirements, we are unwilling to say that such a failure should be held to constitute a per se violation of ERISA. Instead the nature and the consequences of a failure to follow required procedures should be evaluated under a totality of circumstances.”
1 later decision quote this exact passage · from the majority“Here, our job is indeed complicated by the administrator’s failure to reduce the plan to writing, but there is no indication that [defendant’s] failure in this regard was the product of bad faith, nor does it appear that [defendant] attempted to shirk its responsibilities under the terms of the plan____ Accordingly, estoppel is too severe a sanction.”
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.