Mead Corp. v. Tilley

Mead Corp. v. Tilley, 490 U.S. 714 (1989), is a US labor law case, concerning occupational pensions.

Judgment
Justice Thurgood Marshall, writing for the Court, held that only after an employer has met PBGC conditions to fund plans can it recoup ‘excess’ funds that would not need to cover promised benefits.

Justice John P. Stevens dissented.

"In my opinion the early retirement benefits that respondents seek are contingent liabilities that under both ERISA and the Plan must be satisfied before plan assets revert to the employer. Section 4044(d) of ERISA provides that residual assets of a plan may revert to the employer only if three conditions are satisfied, including that 'all liabilities of the plan to participants and their beneficiaries have been satisfied' and 'the plan provides for such a distribution in these circumstances.' 29 U.S.C. § 1344(d). Under the Plan, '[a]ny surplus remaining in the Retirement Fund, due to actuarial error, after the satisfaction of all benefit rights or contingent rights accrued under the Plan, . . . shall . . . be returnable to [Mead].' App. 63 (Plan, Art. XIII, § 4(f))."