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GM Wins Pension Benefit Challenge; Split Sixth Circuit Finds No ERISA Plan
Bloomberg BNA 
Jan. 18, 2015
"A group of retired autoworkers lost their bid for additional pension benefits because the arrangement under which they sought benefits wasn't an ERISA plan ... Judge Eric L. Clay, writing for the two-judge majority, emphasized that the retirees claimed benefits only under the [Special Attrition Program (SAP)] and not under GM's larger pension plan. Because the SAP itself didn't provide retirement benefits and therefore didn't qualify as a plan governed by [ERISA], Clay found that the retirees' claims were properly dismissed." [Buchanan v. General Motors, LLC, No. 13-1664 (6th Cir. Jan. 7, 2015, unpublished)]
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