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Brief of Hospitals to Supreme Court in Consolidated Church Plan Cases (PDF)
SCOTUSblog Link to more items from this source
Jan. 20, 2017

79 pages. "Nothing in the statute requires 'churches' to establish pension plans for affiliated organizations; to the contrary, the text is incompatible with such a requirement.... Nothing in ERISA's history supports such a requirement. And such a requirement would serve no apparent purpose, beyond arbitrarily excluding certain plans maintained by religious organizations. It is entirely unclear what church establishment even means and if it is anything more than an empty formalism." [Advocate Health v. Stapleton, Nos. 16-74, 16-86, 16-258 (on appeal to Supreme Court)]

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