Vallone v. CNA Financial Corp.
United States Court of Appeals for the Seventh Circuit
375 F.3d 623 (7th Cir. 2004)
Continental (defendant, later acquired by CNA) orally told employees considering its 1992 early-retirement program that a monthly Health Care Allowance (HCA) benefit was a lifetime benefit, without mentioning revocability, even though Continental's own written 1992 Retirement Guide — incorporated into the program — explicitly reserved the company's right to amend or revoke retiree benefits at any time. After CNA acquired Continental and later revoked the HCA benefit in 1999, 347 employees (plaintiffs) who'd taken early retirement sued under ERISA, equitable estoppel, and breach of fiduciary duty; the district court granted CNA summary judgment, and the employees appealed.
Whether, under ERISA, an employer's oral promise of a lifetime retirement benefit causes the benefit to vest if the employer simultaneously reserves the right to modify or revoke the benefit.