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9th Circuit Says No Vested Right to Health Benefits = No Standing = No Subject Matter Jurisdiction
Alaska Employment Law 
[Guidance Overview] Sept. 23, 2008
Excerpt: The 9th Circuit has held that the employer's ability to modify the vesting of early retiree health benefits deprived the retirees of standing, and thus deprived the District Court of subject matter jurisdiction over their claim of wrongful termination of those benefits.
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