13 pages; Smathers v. Multi-Tool, Inc., No. 01-1045 (3d Cir. Jul. 31, 2002). Excerpt: Here, there was no right that vested, nor is there any issue of retroactivity since the administrator"s discretionary authority was in place when that discretion was exercised. We also note that this reasoning is consistent with our view that the concept of 'vesting" under benefit plans is to be narrowly applied, and that there is a presumption against vesting with respect to most aspects of such plans.  MORE >>