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    Becker v. Mack Trucks Inc
    Filed February 21, 2002
    
    UNITED STATES COURT OF APPEALS
    FOR THE THIRD CIRCUIT
    
    No. 00-4414
    
    LARRY BECKER; STEPHEN CAPKOVIC, III; LEE R.
    CHRIST; JAMES DAQUISTO; MICHAEL DREHER; RANDY
    FREY; ROBERT GASTON; CHARLES GROHOTOLSKI;
    BARRY JONES; JOHN JUDD; DENNIS KNOPF; WAYNE
    LABATY; WILLIAM LEHMAN; THOMAS LITCHAUER;
    BRUCE MCFARLAND; MICHAEL MEYERS; SAMUEL
    OLIVERIA; ROBERT PETERS; SHERWOOD PETERS;
    THOMAS ROBERTS; KATHERINE TAKACS; SCOTT
    TAKACS; ANTHONY TRATNYEK; CLAIRE WILLIAMS;
    DENNIS C. ACKER; RICHARD BALLIET; ALEXANDER
    BANDI, JR.; STEPHEN R. BECKER; TIMOTHY S. BELLER;
    ANITA L. BELLES; THOMAS F. BENNER, JR.; JUDITH A.
    BINDER; DAVID J. BOBO; JAMES P. BURGER, JR.;
    RALPH A. CHRISTMAN; LAVERN R. CLATER; ALFRED W.
    DILABIO; MICHAEL A. DILCHER; WAYNE R. ERNST;
    DANIEL H. FREED; EDWARD A. FREED; JOHN L.
    GOLDEN; MANUEL I. GUEDES; DENNIS P. HAFER;
    SHEILA K. HANSLER; CLAYTOR HOWARD; JEFFREY
    HUSACK; JAMES P. KALAVODA; JOZEF KAZIMIR; JOHN
    S. KERBACHER; ANTHONY A. KISS; JOSEPH J. KISS;
    STEPHEN J. KISS; MICHAEL KLUCAR; DENNIS G.
    KOEHLER; ANDREW J. KORUTZ; RICHARD D. DRATZER;
    THOMAS A. MARSHMAN; RONALD P. MARCKS; JAN A.
    MERKEL; JANE L. MICHAEL; CHESTER C. MILLER; PAUL
    J. MISHKO, JR.; DENNIS R. PASCOE; THOMAS E.
    PRUZINSKY; JOSEPH M. RICE; BRUCE L. ROTHROCK,
    JR.; EDWARD R. SAJT; GERALD ROBERT SCHUECK;
    PETER M. SINCLAIR; DAVID W. SMITH; DALE R.
    SNYDER; MARYANN J. SOSNOWSKI; DARREL C.
    STOFFLET; GEORGE M. SZEP; JOHN J. SZILAGYI;
    BRUCE TORRENCE; CHERYL A. YANDRASITS,
    
           Appellants
    
    
    
    
    v.
    
    MACK TRUCKS, INC.
    
    Appeal from the United States District Court
    for the Eastern District of Pennsylvania
    (D.C. Civil Action No. 00-cv-01338)
    District Judge: Honorable Franklin S. VanAntwerpen
    
    Argued September 26, 2001
    
    Before: ROTH, AMBRO and FUENTES, Circuit Judge s
    
    (Opinion filed: February 21, 2002)
    
           Quintes D. Taglioli, Esquire (Argued)
           Markowitz & Richman
           512 Hamilton Street, Suite 200
           Allentown, PA 18101
    
            Attorney for Appellants
    
           Edward T. Ellis, Esquire (Argued)
           Jeanne L. Bakker, Esquire
           David E. Brier, Esquire
           Montgomery, McCracken, Walker &
            Rhoads, LLP
           123 South Broad Street
           Philadelphia, PA 19109-1090
    
            Attorneys for Appellee
    
           Mary Ellen Signorille, Esquire
           American Associaiton of Retired
            Persons
           601 E. Street, N.W.
           Washington, D.C. 20049
    
            Attorney for Amici-Appellants
           American Association of Retired
           Persons and National Employment
           Lawyers Association
    
                                    2
    
    
    OPINION OF THE COURT
    
    ROTH, Circuit Judge:
    
    This case requires us to decide whether S 510 of the
    Employee Retirement and Income Security Act, 29 U.S.C.
    S 1140, applies to rehiring decisions. Plaintiffs are former
    employees of defendant Mack Trucks, Inc., who lost their
    jobs when Mack closed its Allentown plant in 1987. Some
    plaintiffs had vested pension rights at the time they were
    laid off. Others merely had credit for past service. In 1997,
    when the economy had improved, Mack needed to hire
    workers for its Macungie plant. By this time, all the
    plaintiffs had either exhausted or forfeited any recall rights
    with Mack. Mack declined to rehire plaintiffs because to do
    so would create a future pension liability disproportionately
    greater than that incurred by hiring employees without past
    service or pension credit. Plaintiffs contend that Mack's
    decision amounts to unlawful "discrimination" under S 510
    of ERISA.
    
    The District Court rejected plaintiffs' claims in their
    entirety on a motion for summary judgment. We will affirm
    that decision. We agree, as an initial matter, that those
    plaintiffs without vested pension rights lack standing to
    pursue their S 510 claim. See Shawley v. Bethlehem Steel
    Corp., 989 F.2d 652 (3d Cir. 1993). Shawley  does not
    foreclose standing for those plaintiffs with vested rights,
    however; thus, we reach the merits of their claims and
    resolve the question left unanswered in Shawley:  Whether
    an employer's refusal to rehire based on a desire to avoid
    increased pension liability is prohibited activity under
    S 510. Id. at 655 n.5. We conclude that S 510 does not
    proscribe Mack's refusal to rehire the vested plaintiffs.
    
    I. FACTS
    
    Defendant Mack Trucks manufactures and distributes
    heavy-duty trucks. It operates an assembly plant in
    Macungie, Lehigh County, Pennsylvania, and, until 1987,
    operated machining and fabrication plants in Allentown,
    
                                    3
    
    
    Pennsylvania. Employees in both locations are and were
    represented by the United Automobile, Aerospace and
    Agricultural Implement Workers (UAW) and UAW Local 677.
    The plants in Allentown and Macungie were covered by the
    Mack-UAW Master Agreement as well as by local
    agreements.
    
    The Master Agreement includes, as Appendix A, the
    Mack-UAW Pension Plan, which is subject to renegotiation
    every time the Master Agreement itself is renegotiated. Prior
    to January 1, 1989, an employee covered by the Plan
    became vested under the Plan after ten years of service. On
    and after January 1, 1989, employees became vested after
    five years of service. The Plan also provided that any
    rehired former employee would be entitled to credit for past
    service no matter how long the break between employment
    periods.
    
    When Mack closed its facilities in Allentown in 1987, a
    number of employees lost their jobs. Some transferred or
    were absorbed into other Mack plants. Others, like the
    plaintiffs, either accepted a cash "dislocation benefit" to
    relinquish their seniority rights or were laid off and
    eventually exhausted their recall rights. Some plaintiffs
    were laid off before meeting the ten year vesting
    requirement in place at the time; other plaintiffs were fully
    vested by the time they were laid off.
    
    In 1997, a combination of rising production needs and
    workforce attrition made it necessary for Mack to hire new
    employees at the Macungie plant. Although Mack's former
    employees were initially the first to be offered new jobs,
    Mack soon realized that a rehired former employee with
    credited service under the Plan would receive a
    disproportionately larger pension than would a newly hired
    employee.
    
    There are three reasons for this difference in pension
    benefits between former employees and new hires. First,
    former employees who had not vested under the Plan would
    receive credit for past service and would become vested in
    less than the five years applicable to new hires. 1 Second,
    _________________________________________________________________
    
    1. Because the Plan's vesting period of ten years employment had been
    reduced to five years in 1989, the unvested former employees with
    between five and ten years credited service would be credited on rehire
    with past service sufficient for vesting.
    
                                    4
    
    
    former employees were more likely to become eligible for
    early retirement before age 62. Third, former employees
    would be entitled to raise their pension rate on retirement
    above the lower benefit rate in place as of the day they had
    been laid off in 1987.
    
    As a result, in July of 1997 Mack decided to stop hiring
    former employees with credited service under the plan. All
    78 plaintiffs are former Mack employees who were not
    considered for re-employment due to Mack's pension
    liability avoidance policy.
    
    The plaintiffs brought a complaint seeking injunctive and
    monetary relief based on allegations that Mack violated 29
    U.S.C. S 1140 when it refused to rehire them. After Mack
    filed a timely answer admitting the essential facts of the
    complaint, the parties brought cross-motions for summary
    judgment and asked the District Court to rule on a core set
    of stipulated facts. On November 30, 2000, the District
    Court found that Mack's decision not to rehire plaintiffs
    was not unlawful and entered judgment in favor of Mack.
    Plaintiffs filed a timely appeal.
    
    II. JURISDICTION AND STANDARD OF REVIEW
    
    We have federal question jurisdiction over this case
    under 28 U.S.C. S 1331 because plaintiffs have alleged a
    violation of S 510 of ERISA, 29 U.S.C. S 1140. We also have
    appellate jurisdiction to review the District Court's
    November 30, 2000, order granting summary judgment
    under 28 U.S.C. S 1291.
    
    The cross-motions for summary judgment were
    submitted with no dispute as to a core set of stipulated
    facts, and the District Court resolved only issues of law in
    its ruling. As a result the standard of our review for the
    District Court's decision is plenary. See West American
    Insurance Co. v. Park, 933 F.2d 1236, 1238 (3d Cir. 1991).
    
    III. DISCUSSION
    
    A. STANDING
    
    We first address whether the non-vested plaintiffs have
    standing to sue under S 510. A plaintiff may bring a civil
    
                                    5
    
    
    action under S 510 of ERISA if he is a "participant or
    beneficiary" of a benefit plan. 29 U.S.C. S 1132 (a)(1)(B). The
    statute defines a participant as "any employee or former
    employee of an employer . . . who is or may become eligible
    to receive a benefit of any type from an employee benefit
    plan . . ." Id. at S 1002(7).
    
    While there is no dispute that the non-vested plaintiffs
    are former employees, it is unclear whether they are
    "participants" under S 1002(7). To resolve this issue we
    must decide whether the non-vested plaintiffs, as former
    employees,2 have (1) a "reasonable expectation of returning
    to covered employment" or (2) " `a colorable claim' to vested
    benefits." Firestone Tire & Rubber Co. v. Bruch, 489 U.S.
    101, 117 (1989). While it is clear that the vested plaintiffs
    have standing under the second element, our opinion in
    Shawley v. Bethlehem Steel Corp., 989 F.2d 652 (3d Cir.
    1993), establishes that the non-vested plaintiffs fail both
    elements of Firestone.
    
    i. Do non-vested plaintiffs have a
           reasonable expectation of returning to
           covered employment?
    
    Like the plaintiffs in Shawley v. Bethlehem Steel Corp.,
    989 F.2d 652 (3d Cir. 1993), the non-vested plaintiffs lack
    a reasonable expectation of returning to covered
    employment. The plaintiffs in Shawley were a group of
    former employees who had been laid off for several years.
    When their previous employer considered rehiring them but
    refused to do so, they sued under ERISA. The employees
    claimed that the employer violated the law by basing its
    hiring decision upon a desire to avoid increased pension
    liability. Shawley, 989 F.2d at 654-55. Under those facts,
    "where the collective bargaining agreement expressly covers
    recall rights, and former employees were not hired before
    the expiration of those rights--we believe plaintiffs had no
    reasonable expectation of reemployment." Id . at 658.
    _________________________________________________________________
    
    2. A current employee who is constructively discharged in violation of
    ERISA need not show a reasonable expectation of returning to covered
    employment to establish standing under ERISA. Berger v. Edgewater
    Steel Co., 911 F.2d 911, 922 (3d Cir. 1990).
    
                                    6
    
    
    The non-vested plaintiffs here are indistinguishable. Their
    collective bargaining agreement also covers recall rights. By
    the time Mack considered rehiring them, all of their recall
    rights had either expired or been waived in lieu of
    dislocation benefits. Thus, under our holding in Shawley,
    non-vested plaintiffs lack a reasonable expectation of
    reemployment.
    
    The non-vested plaintiffs contend nevertheless that their
    reasonable expectation of reemployment and the
    consequent vesting of their benefits would have been
    realized "but for" Mack's refusal to rehire them. In support
    of this proposition, they cite Christopher v. Mobil Oil Corp.,
    950 F.2d 1209 (5th Cir. 1992). Their argument, however,
    ignores our earlier rejection of standing for similarly
    situated plaintiffs even under the Christopher  "but for"
    analysis. Shawley, 989 F.2d at 658-59. As we explained
    there, the "but for" analysis grants standing only when the
    employer's action "in and of itself divests aggrieved parties
    of their status as covered employees." Id. (quoting
    Christopher at 1222).
    
    The "but for" test does not establish standing for former
    employees who are not rehired after being laid off due to an
    economic downturn:
    
           Bethlehem Steel's refusal to rehire [plaintiffs] did not
           "in and of itself " strip [them] of their employee status.
           . . . Plaintiffs were not terminated, constructively
           discharged, or tricked into retiring from Bethlehem
           Steel--they were laid off because of an economic
           downturn in the steel industry.
    
    Shawley, 989 F.2d 659. Thus, even if there were situations
    in which the "but for" test is applicable--a question we
    need not resolve today--it does not support standing for
    plaintiffs here. As in Shawley, Mack's refusal to rehire
    former employees did not "in and of itself " strip them of
    their employee status. The plaintiffs initially lost employee
    status when they were laid off many years earlier.
    
    ii. Do non-vested plaintiffs have a colorable
           claim to vested benefits?
    
    The non-vested plaintiffs also lack a colorable claim to
    vested benefits. To satisfy this element, a claimant"must
    
                                    7
    
    
    have a colorable claim that (1) he or she will prevail in a
    suit for benefits or that (2) eligibility requirements will be
    fulfilled in the future." Firestone Tire & Rubber Co. v. Bruch,
    489 U.S. 101, 117-18 (1989). We have held, under the
    Firestone standard, that non-vested, credited service "gave
    rise to only a forfeitable benefit," and that such a
    "contingent claim for future benefits does not satisfy the
    dictates of Firestone." Shawley, 989 F.2d at 657; see also
    Agathos v. Starlite Motel, 60 F.3d 143, n.10 (3d Cir. 1995)
    ("We have previously held that a claim for credited service
    does not give rise to a `colorable claim' to vested benefits.").
    
    Shawley involved the denial of ERISA standing to a group
    of non-vested former employees. They claimed that credited
    service, which counted as an accrued, forfeitable benefit
    under the rule of parity,3 established standing because that
    benefit was not yet forfeited and would vest under the
    requirements of the Internal Revenue Code if the plan were
    to be terminated prior to the exhaustion of their credited
    service. Shawley, 989 F.2d at 656-57. We rejected this
    argument on the ground that such "contingent" benefits do
    not establish a colorable claim to vested benefits under the
    Firestone standard.
    
    The non-vested plaintiffs attempt to distinguish Shawley
    by claiming that the rule of parity does not apply to their
    benefit agreement with Mack and that they cannot forfeit
    their past credited service because they have the right to
    retain it indefinitely after termination. This distinction is,
    however, without significance. Whether past credited
    service is forfeitable after a given period of time or never
    forfeitable does not change the outcome. "Credited service"
    is not the same thing as the "right to benefits." It is the
    nonforfeitable right to benefits, not the contingent, albeit
    nonforfeitable, right to credited service that is the relevant
    standard under Firestone. And, indeed, when the former
    employees in Shawley brought suit, they had not yet lost
    their right to credit for past service; it remained a
    contingent right until their re-employment within the period
    designated by the rule of parity. Thus, in Shawley we
    determined that a legally unenforceable claim to contingent
    _________________________________________________________________
    
    3. 29 U.S.C. S 1053(b)(3)(D)(i)(II).
    
                                    8
    
    
    benefits cannot establish a colorable claim to vested
    benefits under Firestone. The benefits here, arising from the
    non-vested plaintiffs' credited service, are materially
    indistinguishable from those in Shawley. They are
    contingent upon re-employment with Mack. For that
    reason, the non-vested former employees lack standing.
    
    Nor will we deviate from our opinion in Shawley  based on
    the Supreme Court's intervening decision in Inter-Modal
    Rail Employees Assoc. v. Atchison, Topeka, and Santa Fe,
    520 U.S. 510 (1997). Inter-Modal does not overrule or
    otherwise limit the efficacy of the Court's earlier opinion in
    Firestone or our standing analysis in Shawley. Inter-Modal
    is distinguishable because it does not deal with the
    threshold issue of standing and because it concerns not
    vested pension benefits, but health and welfare benefits,
    which do not vest, and whether health and welfare benefits
    are protected by S 510. Id. at 513.
    
    Thus we reject the non-vested plaintiffs' request for
    standing under the binding authority of Firestone and
    Shawley.4
    
    Because the vested plaintiffs do have standing, however,
    we will now turn to the merits of their claims.
    
    B. MERITS
    
    The vested plaintiffs allege that Mack violatedS 510 of
    ERISA, 29 U.S.C. S 1140, when it refused to rehire them in
    order to avoid increased pension liability. In order to
    demonstrate a prima facie case under S 510, a plaintiff
    must show "(1) prohibited employer conduct (2) taken for
    the purpose of interfering (3) with the attainment of any
    right to which the employee may become entitled." Gavalik
    v. Contintental Can Co., 812 F.2d 834, 852 (3d Cir. 1987).
    In this case, the parties do not dispute that Mack acted
    with the purpose of preventing pension benefit increases to
    previously terminated employees. The only remaining issue,
    _________________________________________________________________
    
    4. The plaintiffs here and in Shawley did not have any enforceable right
    to recall. We are not considering here what impact, if any, an enforceable
    right to recall might have on the standing issue.
    
                                    9
    
    
    then, is whether Mack engaged in prohibited conduct under
    S 510 in its refusal to rehire the vested plaintiffs.
    
    To discern whether Congress intended in S 510 to
    regulate rehiring decisions, "we examine the explicit
    statutory language and the structure and purpose of the
    statute." Ingersoll-Rand Co. v. McClendon, 498 U.S. 133,
    138 (1990). Based on that evidence, we decline to expand
    the reach of S 510 to cover the rehiring of former employees
    with no right or expectation of future employment. See,
    e.g., West v. Greyhound Corp., 813 F.2d 951, 955 (9th Cir.
    1987) ("we hold that no violation of section 510 of ERISA is
    shown where the seller of a business terminates
    employment under the provisions of a collective bargaining
    agreement and the purchaser refuses to hire any of the
    employees because they refuse to accept a reduction of
    unaccrued employee benefits"); Shawley v. Bethlehem Steel
    Corp., 784 F. Supp. 1200, 1202-04 (W.D. Pa. 1992). Both
    the text and purpose of S 510 support the result we reach
    today.
    
    i. The text of S 510
    
    We begin, as we must, with the language of S 510:
    
           Interference with protected rights. It shall be
           unlawful for any person to discharge, fine, suspend,
           expel, discipline, or discriminate against a participant
           or beneficiary . . . for the purpose of interfering with
           the attainment of any right to which such participant
           may become entitled under the plan
    
           . . . .
    
    29 U.S.C. S 1140.
    
    The plain language of S 510 omits a refusal to"rehire,"
    "hire" or to take any action related to hiring from its
    enumeration of prohibited acts. Plaintiffs argue that this
    makes no difference because one definition of
    "discriminate" -- "to make a difference in treatment . . . on
    a basis other than merit," see Webster's Ninth New
    Collegiate Dictionary (1986) -- encompasses hiring
    decisions. We reject this invitation to construe the word
    "discriminate" out of context. Instead, we heed the Supreme
    
                                    10
    
    
    Court's instruction that we "must not be guided by a single
    sentence or member of a sentence, but look to the
    provisions of the whole law, and to its object and policy."
    United States National Bank of Oregon v. Independent
    Insurance Agents of America, 508 U.S. 439, 455 (1993)
    (quoting United States v. Heirs of Boisdore, 49 U.S. (8 How.)
    113, 122, 12 L. Ed. 1009 (1849)). This background makes
    clear that the inclusion of "discriminate" in the text was not
    intended to bear the broad meaning suggested by plaintiffs.
    
    The more limited meaning of "discriminate" becomes
    clear when we consider the manner in which Congress
    traditionally has proscribed discrimination in hiring under
    employment regulatory schemes. When S 510 is compared
    with the statute upon which it was modeled--section 8(a)(3)
    of the National Labor Relations Act, 29 U.S.C. S 158(a)(3)5--
    the omissions in S 510 reveal that Congress did not intend
    to regulate hiring decisions under ERISA.
    
    In the NLRA, Congress specifically stated that it"shall be
    an unfair labor practice for an employer . . . (3) by
    discrimination in regard to hire or to discharge any
    individual or otherwise to discriminate against any
    individual." Id. (emphasis added). Thus, Congress knows
    how to forbid discrimination in hiring, and when it wishes
    to do so it will use the word "hire." Cf. , Meghrig v. KFC
    Western, Inc., 516 U.S. 479, 485 (1996) ("Congress . . .
    demonstrated in CERCLA that it knew how to provide for
    the recovery of cleanup costs, and that the language used
    to define the remedies under the RCRA does not provide
    that remedy.").
    
    Based on Congress's past usage, if Congress intended
    that S 510 apply to hiring practices, it would have included
    the word "hire" in the string of denominated employment
    practices. We agree with the District Court that the express
    _________________________________________________________________
    
    5. "The legislative history of ERISA does make clear . . . that the statute
    was modeled on S 8(a)(3) of the National Labor Relations Act." Stiltner v.
    Beretta U.S.A. Corp., 74 F.3d 1473, 1483 (4th Cir. 1996); 119 Cong. Rec.
    30374 (Statement of Sen. Hartke), reprinted in  2 Legislative History of the
    Employee Retirement Income Security Act of 1974, at 1775 (1976) ("The
    language [of ERISA S 510] parallels section 8(a)(3) of the National Labor
    Relations Act . . . .").
    
                                    11
    
    
    language used to regulate hiring practices in the NLRA, as
    well as other employment statutes,6 implies that the
    omission of such language from S 510 was deliberate.7
    
    ii. The purpose of S 510
    
    We are also convinced that we should reject the vested
    plaintiffs' broad definition of "discriminate" because it
    would "produce a result at odds with the purposes
    underlying the statute." Watt v. Western Nuclear, 462 U.S.
    36, 56 (1983); see also Brotherhood of Locomotive Engineers
    v. Atchison, Topeka, and Santa Fe Railroad, 516 U.S. 152,
    157 (1996) (interpreting statute in accordance with purpose
    of statutory scheme). ERISA is designed to protect benefits
    promised to an employee arising from a pre-existing
    employment relationship. Though the vested plaintiffs once
    had an employer-employee relationship with Mack, their
    complaint does not address a deprivation of any pre-
    existing ERISA or recall rights arising out of their former
    employment.
    
    Instead, plaintiffs seek protection as job applicants. Such
    protection is inconsistent with Congress's purpose in
    enacting ERISA, as evidenced by express statutory
    language, opinions interpreting S 510, and by that
    provision's legislative history. See generally  James F.
    Jorden, Waldemar J. Pflepsen, Jr., & Stephen H. Goldberg,
    Handbook on ERISA Litigation S 8.01 [B]-[C] (2d ed. 2000
    Supplement).
    _________________________________________________________________
    
    6. Other employment statutes that proscribe discriminatory hiring, such
    as Title VII, the Age Discrimination in Employment Act, and the
    Americans with Disabilities Act, do so explicitly. See, e.g., 42 U.S.C.
    S 2000e-2(1) (employer may not "fail or refuse to hire . . ."); 29 U.S.C.
    S 623(a)(1)(same); 42 U.S.C. S 12112 (a) & (b)(5)(B) ("No covered entity
    shall discriminate . . . in regard to job application procedures, the hiring,
    advancement, or discharge of employees; the "term`discriminate'
    includes--(B) denying employment opportunities to a job applicant or
    employee who is an otherwise qualified individual . . .") (emphasis
    added).
    
    7. Thus we need not reach the question of whether"discriminate" is
    similar in nature to the preceding terms "discharge, fine, suspend . . ."
    under the ejusdem generis canon of statutory construction.
    
                                    12
    
    
    As an initial matter, it is axiomatic that "ERISA neither
    mandates the creation of pension plans nor in general
    dictates the benefits to be afforded once a plan is created."
    Smith v. Contini, 205 F.3d 597, 602 (3d Cir. 2000). It is only
    after an employer chooses to provide a pension plan that
    ERISA mandates vesting and other rights designed to
    safeguard employees' expectations with regard to promised
    benefits. Indeed, the explicitly stated policy behind ERISA is
    Congress's desire to protect employees' promised benefits.
    29 U.S.C. S 1001(a).
    
    Section 510 establishes an important check on
    employers' ability to undermine ERISA's protections for
    promised benefits: "Congress viewed [S 510] as a crucial
    part of ERISA because, without it, employers would be able
    to circumvent the provision of promised benefits." Ingersoll-
    Rand Co. v. McClendon, 498 U.S. 133, 143 (1990); Inter-
    Modal Rail Employees Ass. v. Atchison, Topeka, and Santa
    Fe, 520 U.S. 510, 515 (1997) ("S 510 helps make promises
    credible") (citing Heath v. Varity Corp., 71 F.3d 256, 258
    (7th Cir. 1995)). Section 510 safeguards promised benefits
    by prohibiting "unscrupulous employers from discharging
    or harassing their employees in order to keep them from
    obtaining vested pension benefits." Gavalik , 812 F.2d at
    851. Congress has also provided stiff criminal penalties for
    employers that take coercive action to prevent employees
    from obtaining benefits. 29 U.S.C. S 1141; West v. Butler,
    621 F.2d 240, 243 (6th Cir. 1980).
    
    While termination of employment is the prototypical
    action Congress intended to cover in S 510, that section
    also reaches employee harassment which falls short of
    firing. Legislative history reveals that the term
    "discriminate" was used in order to reach conduct "which
    does not say that one is fired, but makes living such a hell
    that a person wishes he did not have to hang on and
    endure," 119 Cong. Rec. 30374 (Statement of Sen. Hartke),
    reprinted in 2 Legislative History of the Employee Retirement
    Income Security Act of 1974, at 1774-75 (1976); 8 see also
    _________________________________________________________________
    
    8. Plaintiffs also claim that S 510's legislative history supports a broader
    interpretation of the term "discriminate." We disagree. The provisions
    upon which they rely discuss "interfer[ence] with [an employee's] rights
    
                                    13
    
    
    McGath v. Auto-Body North Shore, Inc., 7 F.3d 665, 669 (7th
    Cir. 1993) (S 510 "protects the employee not only against
    the classical forms of employer harassment that might
    occasion the loss of benefits, but also against the more
    atypical forms of employer misconduct that can produce
    the same result.").9 Congress's intent to provide a broad
    array of safeguards for existing employment relationships
    by no means suggests, however, that it intended to regulate
    actions taken against a potential employee.
    
    Unlike a discharge or other workplace harassment, a
    failure to hire does not amount to a circumvention of
    promised benefits because job applicants who have yet to
    be hired have not been promised any benefits. In fact, we
    have held that "discriminate" as used in S 510 is "limited to
    actions affecting the employer-employee relationship."
    Haberern v. Kaupp Vascular Surgeons Ltd., 24 F.3d 1491,
    1503 (3d Cir. 1994); accord Fischer v. Philadelphia Elec.
    Co., 96 F.3d 1533, 1543 (3d Cir. 1996) ("under the law of
    this circuit, suits for discrimination under S 510 are `limited
    to actions affecting the employer-employee relationship' ");
    see also Anderson v. Chrysler Corp., 99 F.3d 846, 856 (7th
    Cir. 1996) ("S 510 applies only in instances in which an
    employer wrongfully alters the employment relationship to
    prevent benefits rights from vesting"); Woolsey v. Marion
    Labs, Inc., 934 F.2d 1452, 1461 (10th Cir. 1991) (plaintiff
    had no actionable claim under S 510 when "Administrators'
    _________________________________________________________________
    
    which are protected under the Act," or "discriminatory conduct toward
    participants and beneficiaries which is designed to interfere with the
    attainment of vested benefits or other rights under the bill" H.R. Conf.
    Rep. No. 93-1280, 93d Cong., 2d Sess. (1974) (Joint Explanatory
    Statement of the Committee of Conference), reprinted in 1974
    U.S.C.C.A.N. 5038, 5110 & 5188. These passages contain no suggestion
    that Congress intended to protect the rights of job applicants in addition
    to the rights arising from an employer-employee relationship.
    
    9. To draw on an example from popular culture, consider the plight of
    Milton in Michael Judge's movie Office Space. Although Milton's
    employer had decided to lay him off years ago, his manager never
    bothered to formally discharge him. Instead the company attempted to
    realize its desire to be rid of Milton by moving his office to a dark
    basement and asking Milton to help to get rid of the cockroaches there.
    
                                    14
    
    
    denial has not affected Woolsey's employment situation").10
    The language enacted by Congress simply does not extend
    to actions taken before an employer-employee relationship
    exists.
    
    Our recent decision in Eichorn v. AT&T Corp., 248 F.3d
    131 (3d Cir. 2001), is not to the contrary. That case
    involved a restrictive covenant preventing employees of a
    divested subsidiary company from returning to the parent
    corporation group until after their pension bridging rights
    had lapsed. Id. at 149. The stated purpose of the restrictive
    covenant was to prevent experienced employees from
    leaving the subsidiary when it was purchased by a third-
    party. The third-party, however, determined not to offer a
    defined pension benefit program. Thus, the restrictive
    covenant had the effect of separating the employees from
    the parent company in a manner that eliminated their
    accrued pension benefits. We concluded that plaintiffs had
    averred sufficient facts to state a claim against the parent
    company under S 510.
    
    In sum, S 510 simply does not require that employers
    blind themselves to the effect on future pension liability
    when making hiring decisions. Thus we will implement
    Congress's policy by following the construction ofS 510 that
    is best supported by the text and by the limited purpose of
    ERISA.
    
    IV. CONCLUSION
    
    Plaintiffs, in their ERISA claims, have attempted to
    stretch ERISA's statutory language well beyond the purpose
    _________________________________________________________________
    
    10. The Fifth and Sixth Circuits have stated thatS 510 "reaches further
    than the employment relationship" in cases where plaintiffs are
    discriminated against because they have exercised their ERISA rights.
    Mattei v. Mattei, 126 F.3d 794, 804 (6th Cir. 1997); Heimann v. Nat'l
    Elevator Industry Pension Fund, 187 F.3d 493, 507 (5th Cir. 1999). We
    reject these cases to the extent they conflict with our decision in
    Haberern, which is binding and, we believe, correctly decided. Moreover,
    both the Fifth and Sixth Circuit's holdings are distinguishable from the
    case at hand. They address rights stemming from a pre-existing
    employment relationship, rather than rights arising from a prospective
    employment relationship.
    
                                    15
    
    
    intended by Congress. Today we decline their invitation to
    extend the protections of S 510 of ERISA to cover Mack's
    decision not to rehire plaintiffs. We will, therefore, affirm
    the granting of summary judgment in favor of defendant
    Mack Trucks, Inc.
    
    A True Copy:
    Teste:
    
           Clerk of the United States Court of Appeals
           for the Third Circuit
    
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