## Facts

- Curtis Guidry, a former union official and trustee of a union-related pension plan, pleaded guilty to embezzling union funds in violation of LMRDA § 501(c).
- Guidry’s employment made him eligible to receive benefits from several multiemployer pension plans associated with the union.
- After the conviction, the pension plans asserted that Guidry had forfeited his pension benefits due to his criminal conduct.
- Guidry sued in federal district court under ERISA to recover benefits from two plans.
- The union intervened, joined a third plan, and stipulated with Guidry to entry of a money judgment in the union’s favor.
- The district court rejected forfeiture but imposed a constructive trust in favor of the union on Guidry’s pension benefits until the union’s judgment was satisfied.
- The Tenth Circuit affirmed, reasoning that ERISA’s anti-alienation rule did not bar the constructive trust, and relying in part on ERISA § 409(a) and equitable considerations.

## Issues

1. Whether ERISA § 206(d)(1)’s anti-alienation provision prohibits a federal court from imposing a constructive trust on a participant’s pension benefits to satisfy a union’s judgment for the participant’s embezzlement from the union.
2. Whether ERISA § 409(a) or LMRDA § 501 authorizes an exception that permits such a constructive trust despite ERISA’s anti-alienation command.

## Decision

- The Supreme Court reversed the Tenth Circuit.
- The Court held that imposing a constructive trust on Guidry’s pension benefits violated ERISA § 206(d)(1)’s prohibition on assignment or alienation.
- The Court declined to create a judicial exception to ERISA’s anti-alienation rule based on misconduct or equitable considerations.
- The Court found ERISA § 409(a) inapplicable on these facts because Guidry was not found to have breached a fiduciary duty to the pension plans or caused losses to the plans as distinct legal entities.
- The Court held that a general remedial authorization under LMRDA § 501 could not override ERISA’s specific anti-alienation directive.

## Legal Principles

- ERISA § 206(d)(1) broadly bars assignment or alienation of pension benefits, and equitable devices such as constructive trusts are prohibited absent an express statutory exception.
- Courts may not create equitable exceptions to ERISA’s anti-alienation rule based on the wrongfulness of a participant’s conduct; any additional exceptions are for Congress to enact.
- ERISA § 409(a) addresses liability for breaches of fiduciary duty to the plan and does not justify reaching pension benefits where the participant’s proven misconduct was against a separate entity and not a breach causing plan losses.
- A general statutory remedial clause (such as LMRDA § 501’s “other appropriate relief”) does not displace ERISA’s specific protection of pension benefits from assignment or alienation.

## Conclusion

The Court held that ERISA’s anti-alienation provision prevents a constructive trust from being imposed on a participant’s pension benefits to satisfy a union’s judgment for embezzlement, and it refused to recognize a nonstatutory exception grounded in equity, ERISA § 409(a), or LMRDA § 501.


Guidry v. Sheet Metal Workers Nat’l Pension Fund, 493 U.S. 365 (1990)