Nos. 16-74, 16-86, 16-258 In the Supreme Court of the United States __________________ ADVOCATE HEALTH CARE NETWORK, ET AL., Petitioners, v. MARIA STAPLETON, ET AL. __________________ SAINT PETER’S HEALTHCARE SYSTEM, ET AL., Petitioners, v. LAURENCE KAPLAN __________________ DIGNITY HEALTH, ET AL., Petitioners, v. STARLA ROLLINS __________________ On Writs of Certiorari to the United States Courts of Appeals for the Third, Seventh and Ninth Circuits __________________ BRIEF OF THE GENERAL CONFERENCE OF SEVENTH-DAY ADVENTISTS AS AMICUS CURIAE SUPPORTING PETITIONERS __________________ TODD R. MCFARLAND GENE C. SCHAERR ASSOCIATE GENERAL Counsel of Record COUNSEL S. KYLE DUNCAN GENERAL CONFERENCE STEPHEN S. SCHWARTZ OF SEVENTH-DAY SCHAERR|DUNCAN LLP ADVENTISTS 1717 K Street NW, 12501 Old Columbia Suite 900 Pike Washington, DC 20006 Silver Spring, MD 20904 (202) 787-1060 (301) 680-6321
[email protected] Counsel for Amicus Curiae QUESTION PRESENTED The Employee Retirement Income Security Act of 1974 (“ERISA”) governs employers that offer pensions and other benefits to their employees. “Church plans” are exempt from ERISA’s coverage. 29 U.S.C. §§ 1002(33), 1003(b)(2). For over thirty years, the three federal agencies that administer and enforce ERISA—the Internal Revenue Service, the Depart- ment of Labor, and the Pension Benefit Guaranty Cor- poration—have interpreted the church plan exemp- tion to include pension plans maintained by otherwise qualifying organizations that are associated with or controlled by a church, whether or not a church itself established the plan. The question presented is whether the church plan exemption applies so long as a pension plan is main- tained by an otherwise qualifying church-affiliated or- ganization, or whether the exemption applies only if, in addition, a church initially established the plan.