Roman Catholic Archdiocese of San Juan v. Feliciano

Employees of the Roman Catholic Archdiocese of San Juan filed a class action lawsuit in Puerto Rico courts, alleging that the Archdiocese's pension plan was underfunded and violated the Employee Retirement Income Security Act (ERISA). The Archdiocese defended itself by asserting that the plan was a "church plan" exempt from ERISA. Lower courts in Puerto Rico ruled that the plan did not meet the statutory definition of a church plan because it was not established by a church. The Supreme Court of the United States granted certiorari and, on February 24, 2020, issued a per curiam summary reversal. Relying on Advocate Health Care Network v. Stapleton, the Court held that a plan maintained by an organization controlled by or associated with a church qualifies for the exemption, regardless of who initially established it, and remanded the case.

The U.S. Supreme Court summarily reversed the decision of the Supreme Court of Puerto Rico, holding that the Archdiocese's plan is covered by ERISA's church-plan exemption, and remanded the case for further proceedings consistent with its opinion.

Whether the pension plan maintained by the Roman Catholic Archdiocese of San Juan qualifies as a "church plan" exempt from the requirements of the Employee Retirement Income Security Act (ERISA) under 29 U.S.C. § 1003(b)(2).

The ruling reinforced a broad interpretation of the church-plan exemption, providing significant legal certainty for thousands of religiously affiliated hospitals, universities, and charitable organizations across the United States by shielding their pension plans from onerous federal funding, vesting, and reporting obligations.