No. 23-1209October Term 2025Decided May 21, 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
- 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
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.
Vote
- Vote split
- 9-0
- Majority author
- Ketanji Brown Jackson
Opinion documents
Related cases




Grounding
- Grounding
- Primary materials plus reporting.
- Note
- Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
- Checked
- Jul 2, 2026
- Method
- Methodology
Primary materials10
Supreme Court docket 23-1209
docket | Jul 5, 2026
Primary case document
Supreme Court document | Jul 5, 2026
Opinion of the Court - KJ
opinion | May 21, 2026
Questions Presented
brief | Mar 8, 2026
Oral Arguments - M & K Employee Solutions v. Trustees of the IAM Pension Fund
audio | Jan 20, 2026
Petition
brief | May 9, 2024
SupremeCourt.gov
official | Jul 2, 2026
SupremeCourt.gov
official | Jul 2, 2026
SupremeCourt.gov
official | Jul 2, 2026
SupremeCourt.gov
official | Jul 2, 2026