Read the Battoni v. IBEW Local Union No. 102 Employee Pension Plan case and answer the following:
1. What were the legal issues in this case? What did the court decide?
2. Since the anti-cutback provisions of ERISA apply only to pensions and not welfare plans, what did changing the conditions under which retiree health care benefits were available run afoul of the anti-cutback rule?
3. In what sense were the accrued pension benefits of these employees reduced?
4. What should the benefit plan have done instead?
