United Refining Co. v. Cottillion

Issue: (1) Whether, as the Third Circuit held below and the Sixth Circuit also has ruled, Section 1054(g) of the Employee Retirement and Security Act's prohibition on a plan "amendment" can include an administrator's interpretation of the terms of a legitimate plan provision - or whether, as the D.C., Seventh, and Ninth Circuits have held, a plan "amendment" under Section 1054(g) refers only to changes an employer makes to plan language; and (2) whether the administrator's new interpretation of the plan was reasonable, subject to deference under Conkright v. Frommert, and not grounds for a claim under either Section 1054(g) or Section 1132(a)(1)(B) that it denied participants benefits due under the terms of the plan.