Allied Structural Steel Co. v. Spannaus

Case Date: 04/25/1978
Docket No: none

Facts of the Case 

In 1974, Minnesota adopted legislation which required private employers to pay a fee if they terminated employee pension plans or if they moved their offices from the state, leaving insufficient funds to cover pensions for ten-year employees. This law affected Allied Structural Steel as the company began closing offices in Minnesota. Even though the employees affected by the closing were not entitled to pensions under the terms of their employment with the company, according to the Minnesota law, they were. The company was ordered to pay approximately $185,000 to comply with the statute's provisions.

Question 

Did Minnesota's Private Pension Benefits Protection Act violate the Contract Clause of the Constitution?

Argument Allied Structural Steel Co. v. Spannaus - Oral ArgumentFull Transcript Text  Download MP3Allied Structural Steel Co. v. Spannaus - Opinion AnnouncementFull Transcript Text  Download MP3 Conclusion  Decision: 5 votes for Allied Structural Steel Co., 3 vote(s) against Legal provision: Article 1, Section 10, Paragraph 1: Contract Clause

The Court found that the Minnesota law did violate the Constitution as it "substantially altered" the provisions of pension agreements which Allied Steel had with its employees. Citing the importance that the Framers placed on private contracts in the conduct of business, Justice Stewart found that the act's effect was "severe" as it nullified terms of t he company's obligations to its employees and imposed an "unexpected liability in potentially disabling amounts." Furthermore, the law was narrowly targeted at employers who had decided to establish employee pension plans, and it did not seek to deal with broad economic and social problems.