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Another Court Finds Pension Plan of Church-Affiliated Hospital Is Subject to ERISA
The Lowenbaum Partnership and FRA PlanTools 
Jan. 5, 2015
"Ruling in line with the courts in Rollins v. Dignity Health and Kaplan v. Saint Peter's, the court here finds that only a church may establish a church plan. Because Advocate Health acknowledges that it is not a church, it therefore cannot sponsor a plan that falls within the church plan exemption to ERISA." [Stapleton v. Advocate Health, No. 14-C-0187 (N.D. Ill. Dec. 31, 2014)]
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