NJ Federal Court Rules Pension Plan Established By Church-Controlled Hospital Not an ERISA-Exempt Church Plan

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On March 31, 2014 the U.S. District Court in New Jersey held that a defined benefit pension plan established by St. Peter’s Healthcare System was not a church plan exempt under ERISA despite the fact that St. Peter’s is controlled by and associated with the Roman Catholic Church and its employees are considered employees of the Roman Catholic Church. Kaplan v. St. Peter’s Healthcare Sys., 2014 U.S. Dist. LEXIS 44963.

The suit arose from a claim by a former St. Peter’s employee that the pension plan was under-funded to the tune of $70 million. St. Peter’s moved to dismiss the complaint on the grounds of lack of subject matter jurisdiction claiming that the pension plan is an ERISA-exempt church plan. The Court denied St. Peter’s motion and found that the plan did not qualify as an ERISA-exempt church plan.

The Court focused its analysis on the plain meaning of ERISA’s church plan exemption and held that “Congress has explicitly provided two ways to fall within the church plan exemption: (1) a plan established and maintained by a church, or (2) a plan established by a church and maintained by a tax-exempt organization, the principal purpose or function of which is the administration or funding of the plan, that is either controlled by or associated with the church.” The Court held that St. Peter’s satisfied neither of these requirements because, while St. Peter’s sponsored the plan and is controlled by and associated with the Roman Catholic Church, the plan was not established by the Church in the first instance and therefore is not an ERISA-exempt church plan. Judge Shipp relied on a recent decision by a federal court in California which found that ERISA “requires that a church establish a church plan …[defendant’s] effort to expand the scope of the church plan exemption to any organization maintained by a church-associated organization stretches the statutory text beyond its logical ends.” The Court declined to defer to an IRS Ruling that St. Peter’s plan was an ERISA-exempt church plan.

Sponsors of defined benefit pension plans, especially those plans that converted to church plan status, should review the status of these plans to confirm that they comply with ERISA and the “established by a church” requirement.

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Tax

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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