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Employment Law: Battoni v IBEW Local Union No 102

Read the Battoni v. IBEW Local Union No. 102 Employee Pension Plan case and answer the following:
1. What were the legal issues in this case? What did the court decide?
2. Since the anti-cutback provisions of ERISA apply only to pensions and not welfare plans, what did changing the conditions under which retiree health care benefits were available run afoul of the anti-cutback rule?
3. In what sense were the accrued pension benefits of these employees reduced?
4. What should the benefit plan have done instead?

Solution Preview

1. The primary legal issue in this case was whether or not the amendment that was implemented or added to their present welfare plan resulted in an unlawful or illegal cutback in the accrued benefits that were were earned by these individuals under the provisions of their benefits plan. In addition, there was the legal issue as to whether or not this amendment resulted in a violation of the Anti-Cutback Rule. The court had to essentially decide if the amendment was in violation of any of the stipulations of the anti-cutback rule. The District Court ruled that the amendment did ...

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