Rosenblatt v. United Way of Greater Houston
Stanley Rosenblatt, a long-time employee of the Jewish Community Center, participated in United Way of Greater Houston's defined benefit pension plan. In 1995, United Way converted this to a cash balance plan (CB Plan) due to a significant funding deficit, later adding a "wear-away" provision and freezing accruals. Rosenblatt alleged age discrimination with the EEOC, claiming the CB Plan adversely affected older employees by reducing benefit accruals and miscalculating benefits. United Way filed motions to dismiss, arguing that Rosenblatt failed to state a claim under ERISA and ADEA, citing circuit court precedents upholding cash balance plans as non-discriminatory. The Court sided with United Way, concluding that Rosenblatt's claims regarding benefit accruals, notice requirements, minimum participation standards, and breach of fiduciary duty lacked sufficient factual basis under ERISA and ADEA. Consequently, the defendants' motions to dismiss were granted, and the case was dismissed.