"The plan administrator had been interpreting the plan terms to provide for an unreduced pension benefit commencing before age 65. In connection with certain plan restatements, a provision was added to the plan to provide for actuarially reduced benefits for those who commenced benefits prior to normal retirement age. The plan's actuaries subsequently informed the plan administrator that paying unreduced pensions jeopardized the plan's tax qualified status. The plan administrator thus informed individuals who had already retired that they could commence benefits, but at an actuarially reduced amount.... The Third Circuit, affirming the district court's decision, held that the plain terms of the pre-amended plan document provided for an unreduced pension." [Cottillion v. United Refining Co., Nos. 13-4633, 13-4743 (3d Cir. Mar. 18, 2015)]