## Facts

- Maine enacted a plant-closing statute requiring certain employers to make a one-time severance payment to employees not covered by an express severance contract.
- Fort Halifax Packing Company operated a poultry processing plant in Winslow, Maine.
- Fort Halifax closed the plant and laid off most employees, triggering the statute’s conditions.
- Maine’s Bureau of Labor Standards Director sued in state court to enforce the severance-payment requirement for affected employees.
- Fort Halifax did not dispute that the statute applied; it argued the law was preempted by ERISA and the NLRA.

## Issues

1. Whether Maine’s one-time severance-payment statute is preempted by ERISA as a state law that “relate[s] to” an employee benefit plan.
2. Whether the statute is preempted by the NLRA on the theory that severance pay is reserved to the federal collective-bargaining regime.

## Decision

- The Supreme Court affirmed the state-court judgment enforcing the statute.
- ERISA did not preempt the statute because the law did not have the required connection with, or reference to, an ERISA “plan.”
- The statute required only a one-time, non-discretionary payment triggered by a single event and did not require an ongoing administrative program.
- The NLRA did not preempt the statute because it functioned as a permissible state minimum labor standard rather than regulation of collective bargaining.

## Legal Principles

- ERISA preempts state laws only to the extent they “relate to” an employee benefit plan; a law relating to benefits alone is not enough absent a plan connection.
- A one-time lump-sum payment obligation triggered by a single event, requiring no ongoing administrative scheme, generally does not establish or require an ERISA plan.
- ERISA’s preemption purpose is tied to uniform regulation of plan administration and fiduciary standards; those concerns are not implicated without ongoing plan administration.
- State minimum labor standards are generally not preempted by the NLRA merely because they affect bargaining positions or touch mandatory bargaining subjects.

## Conclusion

The Court held that Maine could require a one-time severance payment upon a plant closing because the statute did not mandate an ERISA-covered plan and did not intrude on the NLRA’s collective-bargaining framework.


Fort Halifax Packing Co. v. Coyne, 482 U.S. 1 (1987)