"The Third Circuit recently ruled that a welfare plan amendment which added, as a condition of receiving retiree medical benefits under the plan, the requirement that the participant must elect monthly payments rather than a single lump sum payment under the pension plan, was a constructive amendment of the pension plan which violated the anti-cutback provisions of ERISA section 204(g). Battoni, et al. v.__________, Nos. 08-3743, 09-2030, and 08-3924 (3d Cir. 2/5/2010)."  MORE >>