Nathan Adams is a Partner for Holland & Knight's Tallahassee office.

Without dissent, the U.S. Supreme Court ruled in Advocate Health Care Network v. Stapleton, Case Nos. 16-74, 16-86, and 16-258, 581 U.S. __ (2017), that a church need not have originally established a church plan for it to so qualify. Hundreds of private letter rulings and opinion letters issued since 1982, including several provided to the defendant hospitals in this case, were thereby vindicated against class action lawsuits by current and former employees of the hospitals who alleged that their employers' pension plans do not fall within ERISA's church-plan exemption and, thus, must satisfy the statute's requirements. Justice Kagan delivered the opinion of the court, which hinges on statutory construction of 29 U.S.C. § 1002(33)(C)(i). Justice Gorsuch took no part. Justice Sotomayor filed a concurring opinion agreeing with the reasoning, but concerned about the consequences.

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