Mealey's (August 31, 2015, 1:47 PM EDT) -- MINNEAPOLIS — A Minnesota federal judge on Aug. 26 dismissed a third-party claim filed against an employer for breach of the doctrine of promissory estoppel for failing to pay a health benefits claim because the employee’s claim is one for wrongful denial of health benefits under the Employee Retirement Income Security Act, which cannot be supported because the employee breached his obligations under the plan (Olmstead Medical Center v. Ronald L. Carter et al., No. 14-2916, D. Minn.; 2015 U.S. Dist. LEXIS 112758)....