Central Laborers’ Pension Fund v. Heinz

Thomas Heinz (plaintiff) was a retired participant in a multiemployer pension plan (plan) administered by Central Laborers’ Pension Fund (fund) (defendant). Heinz spent his career in the construction industry and qualified for early retirement based on having accrued sufficient pension credits under a service-only pension scheme. The plan paid Heinz the same monthly benefit he would have received if he had retired at the usual age, although the payments started earlier and were therefore likely to continue longer than the average period. In exchange, the plan barred beneficiaries of service-only pensions from certain types of employment after they retired. Working in a disqualifying job would result in a suspension of benefit payments during the prohibited employment. When Heinz retired in 1996, the plan defined disqualifying employment to include any job as a construction worker but not as a construction supervisor. Heinz took a job as a construction supervisor, and the plan thus continued to pay his monthly benefit. In 1998, however, the plan’s definition of disqualifying employment was expanded to include any job in any capacity in the construction industry. The plan interpreted the amended definition as applicable to Heinz’s employment and warned Heinz that if he continued to work as a construction supervisor, his monthly pension benefits would be suspended. Heinz kept working, and the plan suspended his benefits. Heinz sued the plan under the Employee Retirement Income Security Act of 1974 (ERISA), arguing that applying the new definition to him violated ERISA’s anticutback rule, which prohibited pension-plan amendments that would reduce a participant’s accrued benefit. The district court granted the plan’s motion for judgment on the pleadings, and the appellate court reversed. The United States Supreme Court granted the plan’s petition for certiorari.