by corporation and thus was a “participant” in ERISA plan), with Agrawal v. Paul Revere Life Ins. Co., 205 F.3d 297 (6th Cir.2000) (following earlier case law that sole shareholder/surgeon is neither a participant nor beneficiary and has no standing to sue under ERISA); Fugarino v. Hartford Life & Acc. Ins. Co., 969 F.2d 178 (6th Cir.1992) (finding the health cov erage of sole proprietor of a restaurant and his dependents not subject to ERISA, although coverage for other employees under the same group health plan was); Kwatcher v. Mass. Serv. Employees Pension Fund, 879 F.2d 957 (1st Cir.1989) (sole shareholder was “employer,” not “employee” of corporation and was thus barred from collecting a pension under the corporation’s benefit plan); Giardono v. Jones, 867 F.2d 409 (7th Cir.1989) (<HOLDING>); Peck-ham v. Bd. of Trustees of Int’l Bhd. of
holding that plan administrator of an erisa health plan did not have to anticipate the confusion of a plan participant holding that erisas definition of employer does not include persons other than signatory employers holding the employer breached the duty owed to its employee by erroneously advising the employee he would continue to have coverage for 30 days following his termination of employment under the employers group policy holding that a plan participant may have article iii standing to obtain injunctive relief related to erisas disclosure and fiduciary duty requirements without a showing of individual harm to the participant holding that erisas definition of participant does not include a former employee who became an employer and was allowed to continue purchasing plan coverage