General Electric Company v. Boilermaker-Blacksmith National Pension Trust

── General Electric Company v. Boilermaker-Blacksmith National Pension Trust ── Court: Court of Appeals for the Eighth Circuit Date: May 26, 2026 Category: General United States Court of Appeals For the Eighth Circuit ___________________________ No. 25-1442 ___________________________ General Electric Company Plaintiff - Appellee v. Boilermaker-Blacksmith National Pension Trust Defendant - Appellant ___________________________ Boilermaker-Blacksmith National Pension Trust; John T. Fultz, a fiduciary Plaintiffs - Appellants v. General Electric Company Defendant - Appellee ___________________________ National Coordinating Committee for Multiemployer Plans Amicus on Behalf of Appellant(s) Employer Associations Amicus on Behalf of Appellee(s) ____________  Appeal from United States District Court for the Western District of Missouri - St. Joseph ____________ Submitted: December 17, 2025 Filed: May 26, 2026 ____________ Before GRUENDER, KELLY, and ERICKSON, Circuit Judges. ____________ KELLY, Circuit Judge. Boilermaker-Blacksmith National Pension Trust (the Fund) sought withdrawal assessments under the Employment Retirement Income Security Act of 1974 (ERISA) from General Electric Company (GE), but an arbitrator found GE qualified for an exemption from withdrawal liability. The district court 1 upheld the arbitrator’s decision, and the Fund appeals. We affirm. I. In 1974, Congress passed ERISA “to ensure that employees and their beneficiaries would not be deprived of anticipated retirement benefits by the termination of pension plans before sufficient funds have been accumulated in the plans.” Pension Benefit Guar. Corp. v. R.A. Gray & Co., 467 U.S. 717, 720 (1984) (citing Nachman Corp. v. Pension Benefit Guar. Corp., 446 U.S. 359, 361–62, 374– 75 (1980)). Title IV of ERISA “created a plan termination insurance program, administered by the Pension Benefit Guaranty Corporation (PBGC)” that “collects insurance premiums from covered pension plans and provides benefits to participants in those plans if their plan terminates with insufficient assets to support its guaranteed benefits.” Id. (citing 29 U.S.C. §§ 1322, 1361). 1 The Honorable Brian C. Wimes, then United States District Judge for the Western District of Missouri, now Chief Judge. -2-  Shortly after ERISA’s passage, however, “Congress became concerned that a significant number of [multiemployer pension] plans were experiencing extreme financial hardship,” which could in turn “forc[e] the PBGC to assume obligations in excess of its capacity.” Id. at 721. At congressional direction, the PBGC studied the problem and found “that ERISA did not adequately protect plans from the adverse consequences that resulted when individual employers terminate their participation in, or withdraw from, multiemployer plans.” Id. at 722. If one or more employers left the plan, the remaining employers would still be responsible for paying pension liabilities generated by the departed employers who were no longer participating in the plan. Connolly v. Pension Ben. Guar. Corp., 475 U.S. 211, 216 (1986) (citation omitted). Costs then increased for the remaining employers, providing an incentive for them to leave the plan, as well. See id. Congress responded with the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA), 94 St