Stapleton v. Advocate Health Care Network

Dist. Ct. did not err in finding that defendant-church-affiliated employee benefit plan did not qualify for exemption from ERISA regulations for retirement plans established by actual churches. While church retirement plan is exempted from ERISA regulations in order to prevent excessive government entanglement with religion, defendant’s retirement plan did not qualify as church plan under ERISA, even though defendant was affiliated with Evangelical Lutheran Church of America and United Church of Christ, since defendant was not church, and defendant’s retirement plan was not established by church. As such, defendant’s retirement plan was subject to ERISA regulations.