## Facts

- Individual petitioners performed intermodal cargo-transfer work at a rail yard while employed by Santa Fe Terminal Services, Inc. (SFTS), a wholly owned subsidiary of The Atchison, Topeka and Santa Fe Railway Company (ATSF).
- Petitioners were covered by Teamsters collective bargaining agreements and received pension, health, and welfare benefits under ERISA-governed plans.
- ATSF entered a service agreement with SFTS, then soon terminated it and opened the work to competitive bidding.
- In-Terminal Services (ITS) won the bid; SFTS employees who declined employment with ITS were terminated.
- Petitioners alleged ITS/Teamsters benefit plans were less generous than the prior SFTS/Teamsters plans.
- Petitioners sued, alleging they were discharged with the purpose of interfering with their attainment of benefit rights, in violation of ERISA § 510, including interference with pension benefits and with welfare benefits.

## Issues

1. Whether ERISA § 510 prohibits interference only with rights that are capable of vesting, or also protects participants’ prospective rights under ERISA welfare benefit plans.
2. Whether limiting § 510 to vested (or vesting-capable) benefits is consistent with the statutory text and ERISA’s definitions.

## Decision

- The Supreme Court unanimously reversed the Ninth Circuit’s limitation of § 510 to vesting-capable rights.
- The Court held § 510 is not confined to vested rights and applies to rights under both pension plans and welfare plans.
- The Court remanded for further proceedings, including consideration of whether petitioners had already “attained” certain rights and whether respondents’ conduct legally constituted interference with the attainment of rights.

## Legal Principles

- ERISA § 510’s text prohibits adverse action against a participant “for the purpose of interfering with the attainment of any right” under “the plan”; “plan” includes both pension plans and welfare plans under ERISA’s definitions.
- Courts may not narrow § 510 to vested or vesting-capable rights where Congress used “plan” and “any right,” and welfare plans are within ERISA even though generally exempt from ERISA’s vesting requirements.
- An employer’s ability to amend or terminate a welfare plan does not create an implied limitation on § 510; § 510 targets adverse action against individuals motivated by a purpose to interfere with benefit rights under an existing plan.
- § 510 requires a purpose to interfere; employer actions taken without that purpose (including certain fundamental business decisions) are not barred.
- Whether interference concerns “attainment” of rights may depend on when a participant is considered to have attained the right at issue, a question left for further analysis on remand.

## Conclusion

The Court held that ERISA § 510 protects employees from being discharged or otherwise discriminated against to prevent them from obtaining rights under either pension or welfare benefit plans, rejecting a vesting-only limitation and remanding to address remaining “attainment” and interference questions.


Inter-Modal Rail Emps. Ass’n v. Atchison, Topeka & Santa Fe Ry. Co., 520 U.S. 510 (1997)