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No. 23-1209October Term 2025Decided May 21, 2026

Docket 23-1209October Term 2025 (2025–2026)

M & K Employee Solutions, LLC, et al., Petitioners v. Trustees of the IAM National Pension Fund

The decision gives guidance on how pension funds and employers must handle long-range estimates when calculating withdrawal liability.

Case status

Current stage
Decided
Latest event
Decision released May 21, 2026
Case Accepted
Arguments HeardJan 20, 2026
Decision ReleasedMay 21, 2026
What it's about

The Court is considering a dispute under the Multiemployer Pension Plan Amendments Act about withdrawal liability. The case addresses how pension funds calculate the amount employers must pay when they withdraw from multiemployer pension plans.

Question presented

Whether the pension fund correctly calculated the employer's withdrawal liability under the Multiemployer Pension Plan Amendments Act.

Case path

United States Court of Appeals for the District of Columbia Circuit / Decision released May 21, 2026

Area

Employment Law

Briefing

What it's about

The Supreme Court issued a decision in a dispute over how the IAM National Pension Fund calculated the amount M & K Employee Solutions and related employers must pay to leave a multiemployer pension plan. The opinion addresses how funds may use long-term projections, including expected interest rates and other predictions, when setting withdrawal liability.

Impact

Withdrawal-liability bills can be very large, so the decision matters to employers that leave union pension plans and to the plans that rely on those payments. For example, a staffing company or trucking company may use this ruling to judge the cost of exiting a plan or challenging a bill.

What's next

Lower courts and arbitrators handling similar ERISA disputes will now apply the Supreme Court's framework. Employers and multiemployer pension funds will likely review pending cases, past calculations, and future withdrawal-liability assessments.

What was the main fight in M & K Employee Solutions v. IAM National Pension Fund?

The parties disputed whether the pension fund used the correct method to calculate what the employers owed after leaving the plan.

Who is most affected by this decision?

Employers leaving multiemployer pension plans and the plans' retirees are both affected. The ruling can change the size and predictability of withdrawal-liability bills.

What happens next after the Supreme Court's decision?

Lower courts and arbitrators will use the Court's guidance in similar disputes. Employers and pension funds will likely reassess calculations, settlements, and ongoing challenges.

Decision

Decision record

What the Court decided

The decision gives guidance on how pension funds and employers must handle long-range estimates when calculating withdrawal liability.

Impact

This affects employers leaving underfunded multiemployer pension plans and workers relying on those plans. The Court said actuaries may use later-adopted assumptions in withdrawal liability calculations. For example, a company withdrawing in 2018 could be billed using assumptions chosen after December 31, 2017. Next, pension funds and employers will likely keep disputing how actuarial predictions affect these bills. The ruling resolves a conflict between the D.C. Circuit and the Second Circuit.

Not official Court text.