Lockheed Corp. v. Spink Certiorari to the United States Court of Appeals for the Ninth Circuit

Summary

The Court held that an ERISA § 406(a) violation requires a transaction caused by a fiduciary; that employers act as settlors, not fiduciaries, when amending pension plans; and that paying benefits under an otherwise lawful plan conditioned on employees’ release of employment claims is not a prohibited transaction. It also held that the 1986 amendments prohibiting age-based benefit accrual rules apply prospectively and do not require credit for Spink’s pre-1988 service. The Court reversed and remanded. Justice Thomas wrote the opinion, joined fully by Chief Justice Rehnquist and Justices Stevens, O’Connor, Scalia, Kennedy, and Ginsburg. Justice Breyer, joined by Justice Souter, concurred except as to Part III-B, dissenting from the decision to resolve whether the benefit payments were prohibited transactions and preferring to leave that question for further development below.