Warning

Info

Table of Contents
LegalWriter, HLS '22 |

0 0

Back to briefs

Cont'l Can Co. v. Chi. Truck Drivers, Helpers & Warehouse Workers Union Pension Fund

(1990)

United States Court of Appeals for the Seventh Circuit - 916 F.2d 1154

tl;dr:

The term “substantially all” in 29 U.S.C. § 1383(d)(2) has its specialized legal meaning of “85%” and not the meaning of “50.1%” that was stated in the statute’s legislative history.

Video Summary

ICRAIssue, Conclusion, Rule, Analysis for Cont'l Can Co. v. Chi. Truck Drivers, Helpers & Warehouse Workers Union Pension Fund

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Cont'l Can Co. v. Chi. Truck Drivers, Helpers & Warehouse Workers Union Pension Fund case brief summary.

Enjoy unlimited access with our 14-day free trial.

Facts & HoldingCont'l Can Co. v. Chi. Truck Drivers, Helpers & Warehouse Workers Union Pension Fund case brief facts & holding

Facts:29 U.S.C. § 1383(d)(2) exempts a pension fund from withdrawal...

Holding:Holding (Easterbrook): The term “substantially all” in 29 U.S.C. §...

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Cont'l Can Co. v. Chi. Truck Drivers, Helpers & Warehouse Workers Union Pension Fund case brief summary.

Enjoy unlimited access with our 14-day free trial.

DeepDiveHighlight a legal term to see the definition

Font size -+
Cont'l Can Co. v. Chi. Truck Drivers, Helpers & Warehouse Workers Union Pension Fund | Case Brief DeepDive
Majority opinion, author: EASTERBROOK, Circuit Judge.
Level 1
Click below 👇 to DeepDive

The legal case involves a dispute between Continental Can Company and the Chicago Truck Drivers Pension Fund over withdrawal payments. Continental argues that it should not have to make payments unless "substantially all" of the Fund's assets come from employers primarily engaged in the trucking industry. An arbitrator determined that 61.6% of the Fund's assets are attributable to such employers, but Continental argues that "substantially all" means 85%. The district court enforced the arbitrator's award, citing previous cases that have defined "substantially all" as meaning more than 85%. The origin of the relevant statute, 29 U.S.C. § 1383(d)(2), suggests that "substantially all" may be an attractive standard because it allows Members of Congress to say different things to different interest groups. The House and Senate passed a bill in 1980 to establish a system of withdrawal liability for underfunded pension plans, which did not exclude the trucking industry. However, the Senate's bill included a special rule for the trucking business, in the exact language that became § 4203(d)(2). The interpretation of "substantially all" as meaning at least 85% of contributions to a pension plan are made by employers engaged in over the road and short haul trucking was based on its use in other provisions of the tax laws. Senator Durenberger explained why special treatment for the trucking industry is appropriate. After the House and Senate agreed to the language of § 4203(d)(2), it was implied for the first time that "substantially all" means "majority". Senator Durenberger inserted another statement into the Congressional Record clarifying his intent for the special withdrawal liability procedure for the trucking industry. The case highlights the importance of interpreting statutory language and the potential for ambiguity in legal terms.

Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Cont'l Can Co. v. Chi. Truck Drivers, Helpers & Warehouse Workers Union Pension Fund case brief summary.

Enjoy unlimited access with our 14-day free trial.

Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.

Opinion (Concurrence), author: FLAUM, Circuit Judge
Level 1
Click below 👇 to DeepDive

The judge who concurs with the majority decision agrees with their judgment but disagrees with their analysis of legislative motive and operation. According to the judge, the Pension Fund's interpretation of "substantially all" in 29 U.S.C. § 1381 is supported by its plain meaning, which does not imply a bare majority. The judge also argues that examining the legislative history of the statute may not be appropriate or informative as the statute is clear and unambiguous. The judge cites Davis v. Michigan Dept. of the Treasury to support this point. Moreover, the judge notes that the legislative history of § 1381 has a neutral impact on the case, and Continental's reliance on post-enactment statements is not favored. The arbitrator's interpretation of "substantially all" is consistent with the IRS's use of the term in different contexts. The fact that two district courts in the Seventh Circuit have taken a different view than Continental is enough to dispose of the case.

🤯 High points 🤯Key points contributed by students on LSD

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Cont'l Can Co. v. Chi. Truck Drivers, Helpers & Warehouse Workers Union Pension Fund case brief summary.

Enjoy unlimited access with our 14-day free trial.

LSD+ Case Briefs

Features

  • DeepDive for detailed case analysis
  • Over 50,000 existing case briefs
  • Instant briefs for another 6,000,000 cases
  • Highlight dictionary for legal term definitions
  • Social learning with chat and high points

Over 50,000 Cases Briefed

LSD+ gives you access to over 50,000 case briefs, more than anyone else. Be the first to email us the website of a case brief product that offers you more case briefs and we'll give you a free year of LSD+.

14-Day Free Trial

Unlimited access. Read as much content as you want during your trial with no device limitations. Cancel any time during your trial and keep access for the full 14 days.

Integrated Legal Dictionary

Lawyers and judges love to use big words. And Latin, for some reason.

Highlight a legal term in LSD Briefs and get an instant, plain English definition. Try highlighting contract or specific performance. No need to search or read through a list of definitions, simply highlight the words you don’t know and our LSDefine integration will instantly give you a definition to any of over 30,000 legal terms.

DeepDive

DeepDive allows you to explore legal cases like never before. DeepDive offers multiple levels of case summaries, which empowers you to quickly and easily find the information you need to stay on top of readings. Easily navigate through summary levels and click on any text to get more detail, all the way down to the original legal case text.

Brief anything. Instantly.

Our proprietary state-of-the-art system can instantly brief over 6,000,000 US cases. That means we can probably brief that case that your professor assigned last night when she sent you a poorly scanned pdf and told you to read every third paragraph. Or maybe she uploaded it to Canvas and didn’t really tell you to read it, but you know you probably should. Tenure does wild things to good people.

Social Learning with Chat and High Points

Study groups are a great way to learn and explore a case. LSD has chat rooms for each case to let you ask questions across the community and hear what other students struggled with and how they put it all together. Learn the key points of every case from other LSD+ users and share your knowledge with LSD High Points.

Real-Time Brief Feedback

Don’t settle for mistakes in briefs that have been there for 10 years and never fixed. Find an issue or something missing from a brief? Down vote and we will make improvements. All of our case brief editors graduated from from T14 law schools.

Cont'l Can Co. v. Chi. Truck Drivers, Helpers & Warehouse Workers Union Pension Fund

Chat for Cont'l Can Co. v. Chi. Truck Drivers, Helpers & Warehouse Workers Union Pension Fund
brief-354
👍 Chat vibe: 0 👎
Help us make LSD better!
Tell us what's important to you
LSD+ is ad-free, with DMs, discounts, case briefs & more.