International Brotherhood of Teamsters, Chauffeurs, Warehousemen and Helpers of America v. Daniel case brief

International Brotherhood of Teamsters, Chauffeurs, Warehousemen and Helpers of America v. Daniel case brief summary
439 U.S. 551 (1979)

CASE SYNOPSIS

Petitioners, an international union, a local union, and a pension plan trustee, sought review of an order denying a motion to dismiss respondent employee's claims brought pursuant to federal securities law violations, which was affirmed by the United States Court of Appeals for the Seventh Circuit.

CASE FACTS

• Respondent filed a complaint, alleging that petitioners had misrepresented and omitted to state material facts with respect to the value of a covered employee's interest in a pension plan. 
• The complaint alleged violations of, inter alia, § 10 (b) of the Securities Exchange Act of 1934, 15 U.S.C.S. § 78j(b), and § 17(a) of the Securities Act of 1933, 15 U.S.C.S. § 77q. 
• Petitioners moved to dismiss on the ground that respondent had no cause of action under the securities law.
• The order denying this motion was affirmed by the court of appeals. 

ISSUE
The issue was whether a noncontributory, compulsory pension plan constituted a "security" within the meaning of the federal securities laws.

HOLDING
The Supreme Court reversed, holding that an employee's interest in a pension plan was not an "investment contract," an instrument that was included in the statutory definitions of security.

CONCLUSION
The decision affirming the denial of petitioners' motion to dismiss was reversed. The federal securities laws were held not to apply to a noncontributory, compulsory pension plan.



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