Martinez v. Bakery & Confectionery Union & Industry International Pension Fund
The case involves multiple plaintiffs, participants in the Bakery and Confectionery Union and Industry International Pension Fund Pension Plan, who challenged an amendment to the plan. This amendment eliminated the ability for participants no longer in covered employment to "age into" certain early retirement benefits (Plan C and Plan G). Plaintiffs alleged this violated Section 204(g) of ERISA, the anti-cutback rule, which protects accrued benefits. The Court, applying the standard for judgment on the pleadings, found that the Plan C and Plan G benefits are early retirement or retirement-type subsidies and thus accrued benefits under ERISA. Relying on statutory text and precedent like *Ahng v. Allsteel, Inc.*, the Court ruled that the amendment impermissibly cut back accrued benefits for those employees who had met the years of service requirement and could continue to age into their pension benefits even after separation from employment. Consequently, the Court granted the plaintiffs' motions for judgment on the pleadings and denied the defendants' motions.