Advocate Health Care Network v. Stapleton, 137 S. Ct. 1652

Petitioners are three church-affiliated nonprofit hospital systems that offer defined‑benefit pension plans established by the hospitals and administered by internal benefits committees.
ERISA generally regulates private pension plans, but exempts "church plans." 29 U.S.C. § 1003(b)(2).
ERISA originally defined a "church plan" as a plan "established and maintained ... by a church." 29 U.S.C. § 1002(33)(A).
A 1980 amendment added that that definition "includes" plans "maintained by" certain church‑affiliated organizations whose principal purpose is administering or funding benefits (a "principal‑purpose organization"). 29 U.S.C. § 1002(33)(C)(i).
Federal agencies long interpreted the amendment to exempt plans maintained by principal‑purpose organizations even if not originally established by a church; employees sued, arguing the amendment did not eliminate the original "established by a church" requirement.
District courts and three Courts of Appeals held for employees; Supreme Court granted certiorari to resolve whether ERISA requires a church to have originally established a plan for it to qualify as a "church plan."

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a plan maintained by a principal‑purpose organization must have been "established by a church" to qualify as a "church plan" under ERISA	The 1980 amendment only expanded "maintained" to include principal‑purpose organizations but preserved the separate requirement that the plan be "established" by a church	The amendment made plans "maintained by" principal‑purpose organizations fall within the definition of "church plan," regardless of who originally established the plan	The Court held that plans maintained by principal‑purpose organizations qualify as "church plans" even if not originally established by a church; the "established by a church" condition does not survive for such plans

Kaplan v. Saint Peter's Healthcare Sys., 810 F.3d 175 (3d Cir. 2015) (court of appeals held church‑establishment required)
Stapleton v. Advocate Health Care Network, 817 F.3d 517 (7th Cir. 2016) (court of appeals held church‑establishment required)
Rollins v. Dignity Health, 830 F.3d 900 (9th Cir. 2016) (court of appeals held church‑establishment required)
New York State Conference of Blue Cross & Blue Shield Plans v. Travelers Ins. Co., 514 U.S. 645 (1995) (overview of ERISA's regulatory framework)
Lozano v. Montoya Alvarez, 572 U.S. 1 (2014) (use of "obvious alternative" drafting as interpretive guide)
Williams v. Taylor, 529 U.S. 362 (2000) (canon: give effect to every clause and word of a statute)
Lockheed Corp. v. Spink, 517 U.S. 882 (1996) (statement of ERISA's protective purpose)
Rose v. Long Island R.R. Pension Plan, 828 F.2d 910 (2d Cir. 1987) (treatment of "establish" and "maintain" as related concepts)