Ruppert v. Alliant Energy Cash Balance Pension Plan, No. 12-3067 (7th Cir. 2013)Annotate this Case
Participants in a cash balance defined benefit pension plan filed a purported class action, alleging that the plan violated ERISA, 29 U.S.C. 1132(a)(1)(B), and seeking recovery of benefits denied the participants as a consequence of the violation. The district judge granted summary judgment in favor of sub‐class A, which challenged the projection rate used by the defendant, and subclass B, which challenged the defendant’s handling of the pre‐mortality retirement discount. A cash balance plan is a “notional” retirement account because individual accounts are not funded; every year the employer adds a specified percentage of the employee’s salary plus interest at a specified rate on the amount in each individual’s notional account. The challenged projection rate and discount rate relate to the entitlement of employees who leave before reaching retirement age. The Seventh Circuit reversed and remanded with respect to the statute of limitations for class members who took lump sum benefits more than six years before the suit was filed and also with respect to the adequacy of the class representatives, but otherwise affirmed.