Bonneau v. Plumbers & Pipefitters Local Union 51 Pension Trust Fund, No. 13-1515 (1st Cir. 2013)
Annotate this CaseThis case concerned a plumbers and pipefitters union ("the Union"), which established employee benefits plans. Among the pension benefits promised to Union employees were "banked hour" benefits, which were retroactively conferred during the course of employment. The Pension Trust sought to eliminate the benefits in an attempt to meet its obligations to a larger group of plan participants. Plaintiffs, now-retired union employees, filed this action against the Trustees, alleging that the cuts, which were effectuated through a plan amendment, violated the anti-cutback provisions ERISA, which protects "accrued benefits" against reduction by amendment. The district court entered summary judgment for Plaintiffs. The First Circuit Court of Appeals affirmed, holding that Plaintiffs' benefits were in fact "accrued" and that the plan amendment, if implemented, would violate the anti-cutback provisions of ERISA.
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