Curtiss-Wright Corp. v. Schoonejongen

The Curtiss-Wright Corporation (defendant) voluntarily maintained a single-employer health plan for retired employees of specific facilities. The terms of the plan were in the plan’s constitution and in the summary plan description. In the plan’s documentation, the company included an amendment provision that stated, “The Company reserves the right at any time and from time to time to modify or amend, in whole or in part, any or all of the provisions of the Plan.” In 1983, enrolled individuals received an updated plan description that included a new termination provision. The provision stated that plan coverage would stop for retirees and their dependents if Curtiss-Wright closed the facility where the retiree had worked. The authors of the new provision did not consider it a formal amendment, and, as a result, the documentation did not indicate whether the change was properly approved. Curtiss-Wright announced the closing of its Wood-Ridge facility and notified retirees from the facility that their postemployment health coverage would be terminated. Frank Schoonejongen and other affected retirees (plaintiffs) filed suit against Curtiss-Wright in federal district court. Schoonejongen claimed that the added provision constituted an amendment to the plan and that no valid amendment procedure was present in the plan’s documentation in violation of the Employee Retirement Income Security Act (ERISA). The district court ruled in favor of Schoonejongen, and the United States Court of Appeals for the Third Circuit affirmed. Curtiss-Wright appealed to the United States Supreme Court.