Mead Corp. v. Tilley

Five employees of the Lynchburg Foundry Company (a subsidiary of The Mead Corporation) were paid a reduced retirement benefit when Mead sold the Foundry and terminated its Industrial Products Salaried Retirement Plan. The issue in the case was "whether . . . [ERISA] requires a plan administrator to pay plan participants unreduced early retirement benefits provided under the plan before residual assets may revert to an employer" when certain benefit plans are terminated. == Judgment ==

Justice Thurgood Marshall, writing for the Court, held that only after an employer has met PBGC conditions to fund plans can it recoup "excess" funds that would not need to cover promised benefits. Citing the test in Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984), the Court held that the statute at issue "in no way indicate[d] an intent to confer a right upon plan participants to recover unaccrued benefits." Justice John P. Stevens dissented. == Subsequent developments ==

The case was remanded to the Fourth Circuit which held ("in harmony with Justice Stevens") that "the Plan's provisions compel satisfaction of the unreduced retirement benefits prior to reversion of the surplus assets." == See also ==