return to work before the six-month STD period had lapsed, and the Court concludes Manning’s LTD interference claim fails as a matter of law. Accordingly, Manning cannot establish a prima facie Section 510 case for interference with LTD benefits because Manning cannot establish that she could have received LTD benefits, let alone was “likely to receive future benefits.” See Fischer, 483 F.3d at 556. Manning has cited no authority to support a Section 510 claim based solely on an employee’s own speculation about her future employment possibilities with her employer. In contrast, ERISA’s public policy supports limiting relief under Section 510 to plaintiffs who can establish clearly ascertainable damages which are foreseeable. See Howe v. Varity Corp., 36 F.3d 746, 756-57 (8th Cir.1994) (<HOLDING>). The number of possible situations that could
holding that no recovery exists for speculative damages holding that erisa provides relief only for clearly ascertainable damages with the intent to make plaintiffs whole which precludes recovery for speculative future harm holding such damages available where local law silent on issue speculative nature of damages does not preclude recovery holding that damages and injunctive relief may be awarded in fair representation cases when necessary to make employees whole holding that the avoidance powers provide for recovery only if the recovery is for the benefit of the estate