Employer interference with ERISA rights and benefits. DiFederico v. Rolm Company

DiFederico v. Rolm Company, 201 F.3d 200 (3rd Cir. 2000): A former employee who contended she was terminated because her employer wanted to avoid the cost associated with long-term disability obligations had to prove that her employer had a specific intent to violate Section 510 of ERISA. Section 510 prohibits an employer from interfering with her attainment of rights or benefits associated with an employee benefit plan. Proving specific intent requires proof that the employer made a conscious decision to interfere, and when there is no direct evidence of that intent, courts apply a shifting burden analysis like the one used in employment discrimination cases. After the former employee makes an initial circumstantial showing that she was terminated for a reason that violated Section 510 and the employer articulates a legitimate reason for its action, the former employee must prove that the employer's reason was pretextual.