United Refining Co. v. Cottillion

(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.