Smith v. Contini, 205 F.3d 597 (3^rd Cir. 2000)-This appeal addressed the issue of reciprocal agreements to combine years of service for pension purposes.  This court reversed the district court's finding that the Teamsters Local 641 Pension Fund's 15-year service requirement for pension benefits did not violate ERISA's maximum 10-year vesting requirement contained in 29 U.S.C. § 1053 (pre-1986 version.)  The 15-year requirement applied to those employees who sought to combine years of service pursuant to the Local 641 Fund's reciprocal agreements with the other pension funds.  Here, Smith, a truck driver filed suit for breach of fiduciary duty after the plan denied him pension benefits both under the "Deferred Benefits" plan (for 10-year Local 641 members) and the "Pro-rata Pension" (for 15-years of combined service).

The district court wrongly interpreted 29 U.S.C. § 1053, to allow a plan to disregard years of service not performed with the Local 641 Fund or a predecessor plan.  This court cited its decision in Hoover v. Cumberland, Maryland Area Teamsters Pension Fund, 756 F.2d 977 (3^rd Cir. 1984) for the finding that combined service credits are "accrued benefits" which, under 29 U.S.C. § 1054(g), a plan amendment cannot decrease.  The court connected this finding to the present case: "Although the concepts of accrued benefits and vested benefits are distinct, the concerns expressed by this court in Hoover have force here"—namely, ERISA's underlying policy goal of protection of retirement benefits.

As for Smith's argument that, in the alternative, the "Deferred Benefits" plan entitled him to benefits, this court agreed with the district court's conclusion that Smith must bring that challenge under 29 U.S.C. §  1132(a)(1)(B), as a denial of benefits, and not in an action seeking equitable relief to remedy a breach of fiduciary duty under 29 U.S.C. § 1132(a)(3).