International Brotherhood of Teamsters, Chauffeurs, Warehousemen and Helpers of America v. Daniel
United States Supreme Court
439 U.S. 551 (1979)
The International Brotherhood of Teamsters (Teamsters) (defendant) negotiated collective bargaining agreements requiring employers to pay into a pension fund on employees' behalf; employees were automatically enrolled, made no contributions themselves, and became eligible for payouts after twenty years of continuous service. Daniel (plaintiff), an employee at one participating employer, disputed whether his service qualified as continuous for the twenty-year requirement and sued the Teamsters for failing to disclose material facts about the plan, alleging a violation of the Securities Act of 1933. The district court ruled for Daniel, and the Seventh Circuit affirmed.
Whether a compulsory, noncontributory pension plan satisfies the Howey test and thus qualifies as a security.