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Supreme Court hears arguments on pension plans under ERISA and venues for patent litigation

[JURIST] The US Supreme Court [official website] heard oral arguments on Monday in Advocate Health Care Network v. Stapleton and TC Heartland LLC v. Kraft Food Brands Group LLC [dockets]. In Advocate Health Care Network v. Stapleton [SCOTUSblog materials], the court heard arguments [transcript, PDF] on whether the Employee Retirement Income Security Act (ERISA) [materials] church-plan exemption applies in circumstances where the qualifying church simply maintains the pension plan instead of establishing it. The case was consolidated with Saint Peter's Healthcare System v. Kaplan and Dignity Health v. Rollins [dockets]. Petitioners argued that it is unnecessary for a church to establish the plan in order for the pension plan to be exempt under ERISA, stating that the government has consistently viewed ERISA as not requiring establishment and that the text and amendments themselves not only do not require establishment but also attempted to fix problems that would arise if establishment of the plan arose. Respondent argued that Congress was very careful in their exception for only church plans and as such there should be a very close tie-in between the church and the plan because Congress did not want to get involved with church affairs. Therefore, in order for a plan to meet the very specific exception of ERISA there should be both a plan established and maintained by the church to meet the singular exception.

In TC Heartland LLC v. Kraft Foods Group Brands LLC [SCOTUSblog materials], the court heard arguments [transcript, PDF] over the rules governing which venues patent infringement lawsuits can be filed. Petitioner argued that the patent venue statute, 28 USC §1400(b) [text], has a statutory phrase on which the court previously ruled on in Fourco Glass Co. v. Transmirra Prods. Corp [opinion]. In that case, Petitioner argued that the court found that the venue "means the state of incorporation only" and is "not to be supplemented by the provisions of 28 USC §1391(c) [text]. Petitioner therefore argued that the current interpretation by the court in Fourco Glass should be maintained as it preserves the original meaning of the statues and supports the court's canon of statutory construction. Respondent in turn argued that §1391(c) applies for all venue purposes including §1400(b) and the Venue Clarification Act is more recent than Fourco Glass and therefore should not be ignored. Therefore, respondent argued that Congress' definition of "residence" expands on venue more than just a place of incorporation and should be used for the purposes of patent litigation under §1391(c).

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