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Sixth Circuit Opinions Applying Estoppel In ERISA Cases - An Anthology
Health Plan Law 
[Guidance Overview] Dec. 9, 2008
Excerpt: The Sixth Circuit has proven to be receptive to the incorporation of estoppel principles into the federal common law of ERISA. In this recent unpublished opinion, the Sixth Circuit panel found the requirements of estoppel met. [Smiljanich v. GMC 2008 U.S. App. LEXIS 24605 (December 5, 2008)] The Court employed a two part test to find that interim employment with other employers did not defeat the bridging of service credits.
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