U.S. Court of Appeals for the Third Circuit

Case Status


Docket Number

13-4633 & 13-4743


Case Updates

Third Circuit holds that calculation of pension benefits violates plain text of ERISA plans

March 18, 2015

The Third Circuit issued a decision holding that an ERISA plan administrator improperly reduced the pension benefits of certain early retirees. The U.S. Chamber filed a brief arguing that the district court erred by failing to give proper deference to the interpretation of the plan administrator under Conkright v. Frommert, 559 U.S. 506 (2010). The Third Circuit, however, held that the plan administrator’s interpretation was incorrect under any approach to the deference question and therefore assumed, without deciding, that Conkright deference applied.

U.S. Chamber files amicus brief

June 18, 2014

The Chamber urged the Third Circuit to vacate and remand the decision of the District Court. The Chamber argued that the decision flouts clear Supreme Court precedent regarding the deference owed to ERISA plan administrators, even after a first mistaken interpretation of a plan. The Chamber pointed out that the decision is problematic because it misapplies a long line of cases requiring courts to defer to an ERISA plan administrator’s reasonable interpretation of plan terms whenever a plan expressly grants the plan administrator interpretative discretion. Additionally, the decision holds that an administrator’s reinterpretation of a plan can actually amend the terms of a plan, locking in prior, mistaken interpretations forever

The Chamber filed the brief jointly with the American Benefits Council and the ERISA Industry Committee.

Craig C. Martin, Matthew J. Renaud, Amanda S. Amert and Jessica Ring Amunson of Jenner & Block LLP represented the U.S. Chamber of Commerce as co-counsel to the National Chamber Litigation Center.

Case Documents