Retirement Plan for Employees of S.C. Johnson & Son, Inc. v. Barberis

(1) Whether a cause of action under ERISA Section 502(a), 29 U.S.C. § 1132(a), accrues when a plan publishes and describes an unlawful change in benefits in its plan materials or only years later when the participant recognizes the legal error; (2) whether, when a plan"s methodology for calculating benefits is deemed void years later and it becomes necessary to determine which of a number of ERISA-compliant formulas the plan would have selected, a court should defer to the view of a plan administrator with "the exclusive right to interpret the Plan and to decide all matters arising thereunder, including without limitation, the power to determine eligibility for benefits under the Plan and the amounts of such benefits" or should instead decide the matter without deference.