Consumers Concrete Corp. v. Central States, Southeast and Southwest Areas Pension Fund

In a legal action involving a multiemployer defined benefit plan, the parties disagreed about the amount owed by the plaintiff under the Multiemployer Pension Plan Amendments Act after the plaintiff withdrew from the defendant’s pension fund. The arbitrator adopted the Fund’s calculation, applying a credit for partial withdrawal at the second step of the Act’s four-step process. The district court vacated that award, accepting plaintiff’s contention that the credit should be applied at the completion of all four steps. The Seventh Circuit affirmed the district court, concluding that the natural reading of the Act favors the latter construction. (EASTERBROOK and RIPPLE, concurring)