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Text of Employees' Brief Opposing Certiorari, Supporting 7th Circuit's Decision in Their Favor (PDF)
Central Laborers' Pension Fund v. Heinz via Appellate.net 
Dec. 1, 2003
27 pages. Excerpt: Although ... it is true that in Spacek v. Maritime Association ... the Fifth Circuit held that 'suspending' pension benefits is not a form of 'reducing' or 'eliminating' those benefits, and thus does not violate the anti-cutback rule, the Spacek decision is in considerable tension with earlier Fifth Circuit precedent and therefore may not be binding even in that Circuit. Petitioner's broad assertions about the importance of this litigation ... have no merit.
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