Continental Can Company, Inc. v. Chicago Truck Drivers, Helpers and Warehouse Workers Union
United States Court of Appeals for the Seventh Circuit
916 F.2d 1154 (1990)
Continental Can (plaintiff) sought an exemption from pension-fund withdrawal liability under 29 U.S.C. § 1383(d)(2), which exempts funds where "substantially all" contributions come from trucking-industry employers; contemporaneous legislative history showed "substantially all" was understood to mean at least 85 percent (its special tax-code meaning), but after the law's enactment, its author stated he intended it to mean merely a majority. Continental Can's fund received a majority, but not 85 percent, of its contributions from trucking employers.
Whether a court may look to legislative history inserted after a statute's passage when interpreting the text of the statute.