Anderson
Anderson v. Suburban Teamsters of Northern Illinois Pension Fund Board of Trustees
Opinion
Opinion
Trott, J.
Bruce Anderson appeals the district court’s determination, following a bench trial, that the Suburban Teamsters of Northern Illinois Pension Fund Board of Trustees (“the Trustees”) did not abuse their discretion in partially denying his claim for disability benefits pursuant to a plan maintained under the Employee Retirement Income Security Act (“ERISA”). In the past, the Plan specified one way to calculate disability benefits. Before Anderson applied for benefits, the Plan was amended to change the formula for calculating benefits depending on the date the employee became disabled. Anderson claims the Trustees improperly determined the date of his disability, resulting in a lower benefit. Anderson claims also that if the Trustees appropriately determined the date of his disability, then the 1999 amendment violates ERISA’s anti-cutback rule. Finally, Anderson claims the Trustees improperly applied a Qualified Domestic Relations Order (“QDRO”), allocating half of his pre-divorce disability benefits to his ex-wife. We affirm.
I
BACKGROUND
For much of his life, Anderson worked as a mechanic. In July 1996, Anderson suffered an on-the-job knee injury that required surgery. In…