Matz v. Household International Tax Reduction Investment Plan

Dist. Ct. did not err in granting defendant-employer’s motion for summary judgment in ERISA class action, alleging that defendant’s series of sales of its subsidiary companies (and its subsequent terminations of employees from said companies) resulted in “partial termination” of class members’ pension plan that in turn resulted in class members obtaining immediate full vesting of their pension benefits. Internal Revenue Service has employed rebuttable presumption that defines partial termination of pension plan as whenever employer reduces/terminates 20% or more of plan participants in its pension plan, and plaintiff’s class representative could show only 5% reduction in plan participants in year in which he was terminated. Moreover, record showed that defendant’s reductions/terminations of class members over three-year period amounted to only 17% of total participants, which was still below 20% threshold for obtaining partial termination treatment.