the trustees which is contrary to the plain words of the controlling document is arbitrary and capricious.”); cf. Lickteig v. Business Men's Assurance Co., 61 F.3d 579, 585 (8th Cir.1995) (noting the similar approaches — significant weight given to plain meaning of the plan in determining arbitrariness and capriciousness of a contrary interpretation-taken by the 4th, 5th and 6th Circuits and citing cases). 10 .GCIU Employer Retirement Fund v. Chicago Tribune Co., 66 F.3d 862, 864-65 (7th Cir.1995) (citing Phillips v. Lincoln Nat'l Life Ins. Co., 978 F.2d 302, 307 (7th Cir.1992) (federal common law rules of contract apply in ERISA actions)); Meredith v. Allsteel, Inc.] 11 F.3d 1354, 1358 (7th Cir. 1993), overruled on other grounds by Ahng v. Allsteel, Inc., 96 F.3d 1033 (7th Cir.1996) (<HOLDING>). 11 . Meredith, 11 F.3d at 1354 (citing
holding that disability benefits are not retirementtype benefits holding that erisa benefits are not property of the estate holding that retirement benefits are accrued benefits under erisa holding that employee spouses accrued but unvested retirement benefits are a contingent property interest and a community asset holding that military retirement benefits are current pay and thus significantly different than other retirement benefits