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... A collective bargaining agreement was first reached in 1962, establishing the "Bert Bell NFL Player Retirement Plan," that "provided enhanced retirement, disability and related benefits to eligible former professional football players." ... Moreover, a 1998 amendment to the Plan was made to specifically address the awarding of disability benefits for head injuries, among other illnesses. ... Civil Action under ERISA Should a former player remain dissatisfied with the outcome of his application, under ERISA, " a civil action may be brought ... by a participant or beneficiary ... to recover benefits due to him under the terms of his plan, to enforce his rights under the terms of the plan, or to clarify his rights to future benefits under the terms of the plan." ... It was not until the spring of 1999 that Webster completed an application for disability benefits under the Plans, applying for Active Football benefits and, in the alternative, Football Degenerative benefits. ... Brent Boyd said "he was even told early in the process by an NFLPA benefits employee that he shouldn't bother filing a claim because "the owners will never open this can of worms by approving a disability claim for a head injury." ... An additional improvement includes a recent decision by the NFL/NFLPA to automatically grant disability claims made by those eligible retirees already receiving social security benefits.

‘Mortal [K]ombat in Cleats’: An Examination of the Effectiveness of the National Football League’s Disability Plan and its Impact on Retired Players