Central Laborers' Pension Fund v. Heinz
Two retirees who had been receiving early retirement benefits from a multi-employer pension fund sued the fund after it implemented a rule change regarding the types of post-retirement employment that triggered suspension of such benefits. The retirees sued under the "anti-cutback" rule of the Employee Retirement Income Security Act (ERISA). The district granted judgment for the fund, and the retirees appealed. The Seventh Circuit Court of Appeals reversed, holding that the fund had expanded its definition of disqualifying employment, in effect reducing early retirement benefits. This reduction violated the anti-cutback rule, when applied to early retirees who had retired prior to the rule change.
Whether an amendment to a multi-employer pension plan that provides for the suspension of the payment of early retirement benefits during the period that a participant, after retiring, is employed by another firm in the same industry is a prohibited elimination or reduction of such benefits under the "anti-cutback" rule in Section 204(g) of the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. § 1054(g), when applied to employees who retired prior to adoption of the amendment.