Seventh Circuit -- John Dennison v. MONY Life Retirement Income Se

Posner solves ERISA quandry with Farnsworth on Contracts, viz:

Despite explicit provision in Plan barring retroactive rejiggering of benefits, Plan can adjust returns, as the lump sum payout is not an accrued benefit.  Consistent practice of parties to the contract justifies same outcome for a parallel benefit.

Theory of conflict of interest too thin to justify additional discovery.

John Dennison v.   MONY Life Retirement Income Se