"[T]he court rejected the plaintiff's collateral estoppel and res judicata claims that she was an employee for purposes of the plan based on a previous state administrative agency's determination that she was an employee in the 1970s and her employer's failure to deny that she was an employee before a state worker's compensation appeal board. The court rejected both arguments noting that 'employee' carries a different meaning under the state worker's compensation statute and that ERISA-covered pension plans are governed by their own terms." [Adams v. General Motors Company, No. 12-2084 (6th Cir. Oct. 24, 2013)]