Partial terminations and Matz v. Household Int'l: is this really a sea change?

Since ERISA's enactment in 1974, employers and employees have bickered over various provisions of benefit plans that are not clearly covered in the statute, such as those involving partial retirement plan terminations. The Seventh Circuit case of Matz v. Household International case (Matz III) will be an important one in partial termination jurisprudence, as it gave a discreet figure at which a presumption of partial termination occurs, and narrowed the factors to be considered in the facts-and-circumstances examination. Hopefully this decision will also finally bring an end to litigation in this case, which has seen four interlocutory opinions (including a brief opinion by the Supreme Court) in its 10-year history. An overview of Matz v. Household International is presented.