Randal Andersen v. Dhl Retirement Pension Plan

The “anti-cutback” rule of the Employee Retirement Income Security Act of 1974 (“ERISA”), 29 U.S.C. § 1054 (g), prohibits any amendment of an employee benefits plan that would reduce a participant’s “accrued benefit.” Our question is whether Defendants’ (collectively, “DHL”) decision to eliminate Plaintiffs’ right to transfer their account balances from DHL’s defined contribution plan to its defined benefit plan violated the rule. We hold it did not.

I.

Plaintiffs are former employees of Airborne Express, Inc. (“Airborne”) who participated in both Airborne’s defined benefit pension plan (“the Retirement Income Plan”) and its defined contri bution plan (“the Profit Sharing Plan”). The Retirement Income Plan is a so-called floor-offset plan. That is, its benefits are calculated on the basis of a participant’s final average compensation and years of service, with an offset for any account balance in the Profit Sharing Plan.

U.S. Dep’t of Labor, Bureau of Statistics, Employee Benefits Survey, People Are Asking ... What is a floor-offset plan?, http://bls.gov/ncs/ebs/peopleboxfloorpl.htm (last modified May 9, 2002). If, for exam-pie, a participant was entitled to receive…