Inter-Modal Rail Employees Assn. v. Atchison, Topeka & Santa Fe Railway Company (1996)
- Docket
- 96-491
- Decided
- 1996-01-01
Summary
Question: Does Section 510 of ERISA bar interference only with vested rights? Conclusion: No. The plain language of Section 510 indicates that the applicability of its interference clause is not limited to vested rights. Congress used the word "plan" to refer to both pension and welfare benefits, and at the same time indicated that welfare plans are exempt from ERISA's stringent vesting requirements. This statutory language forecloses the possibility that Congress meant to limit the protections of Section 510 to vested rights. The Court remanded the case to the Ninth Circuit for determination of whether the fact that the SFTS employees were eligible for welfare benefits meant that they had already "attained" such rights, so that any subsequent actions taken by SFTS could not "interfere" with the "attainment of . . . right[s] . . . under the plan."