Teamsters Local Union No. 705 v. Burlington Northern Santa Fe LLC

Dist. Ct. did not err in dismissing plaintiffs-union and certain union members’ action alleging unlawful interference with union members’ attainment of retirement benefits in violation of section 510 of ERISA, where defendant-employer terminated union members due to lack of contract with third party defendants, and where employer advised plaintiffs that they could apply for their current jobs with third-party defendants at reduced wage and benefit levels. Plaintiffs alleged only unlawful discharge, which presupposes employment relationship with all defendants, and thus plaintiffs had only potential section 510 claim against their employer. Moreover, Dist. Ct. could properly dismiss section 510 claim against employer since complaint merely alleged that employer discharged union members because employer had lost contract with third-parties and not because employer had interfered with union members’ attainment of pension benefits.