Fort Halifax Packing Co. v. Coyne [1987]

482 U.S. 1 · Supreme Court of the United States · United States

Pension and Employee Benefits Lawpension-and-employee-benefits-lawPension and Employee Benefits LawERISA - preemption; state plant closing law; severance pay

Issue

Whether a state law requiring a one-time severance payment upon plant closing is preempted by ERISA.

Held

No, the state law is not preempted because it does not relate to an employee benefit plan; it imposes a one-time payment obligation, not an ongoing administrative scheme.

Exam use

In an exam, introduce Fort Halifax Packing Co. v. Coyne with the citation only if you can remember it accurately; otherwise use the case name and court, then focus on the rule and application. A strong answer should say what Fort Halifax Packing Co. v. Coyne decided, why the facts mattered, and how the authority helps resolve the new facts. Avoid treating the case as a decorative reference. Use it to prove a doctrinal step in ERISA - preemption; state plant closing law; severance pay, then move quickly to analysis.

Summary

Fort Halifax Packing Co. v. Coyne is included in the Pension and Employee Benefits Law case database because it gives students a concrete authority for ERISA - preemption; state plant closing law; severance pay. The reported citation is 482 U.S. 1, and the decision is associated with Supreme Court of the United States. In revision, treat the case as a way to connect the legal issue to a real dispute rather than as an abstract rule. The key exam move is to state the holding, identify the fact pattern that made the rule matter, and then decide whether a new problem question should apply, distinguish, or limit the authority.

Facts

The material factual signal for Fort Halifax Packing Co. v. Coyne is: Maine law required employers to provide a one-time severance payment to employees upon a plant closing. Students should read the linked source and turn that signal into a short fact table: parties, transaction or public-law setting, procedural posture, conduct in dispute, and the fact the court treated as decisive. This prevents vague case-dropping. In an answer on Pension and Employee Benefits Law, use the facts to explain why ERISA - preemption; state plant closing law; severance pay was live, then compare the problem facts against the facts in the case before stating any conclusion.

Procedural History

Fort Halifax Packing Co. v. Coyne is reported as a decision of Supreme Court of the United States. The procedural route should be checked against the linked source before formal citation. For study notes, record whether the decision was an appeal, judicial review, trial judgment, tribunal ruling, or constitutional/application proceeding, because that posture affects how confidently the rule can be used.

Issue

Whether a state law requiring a one-time severance payment upon plant closing is preempted by ERISA.

Held

No, the state law is not preempted because it does not relate to an employee benefit plan; it imposes a one-time payment obligation, not an ongoing administrative scheme.

Ratio Decidendi

A state law that imposes a single, uncomplicated obligation (like a lump-sum severance payment upon plant closing) does not 'relate to' an ERISA plan and is not preempted, because it does not require the creation of an ongoing administrative plan.

Obiter Dicta

Check the linked source for concurring, dissenting, or obiter observations before quoting this case. If the case includes non-binding reasoning, use it as persuasive support rather than as the core rule.

Reasoning

For reasoning, start with the ratio: A state law that imposes a single, uncomplicated obligation (like a lump-sum severance payment upon plant closing) does not 'relate to' an ERISA plan and is not preempted, because it does not require the creation of an ongoing administrative plan. Then read the source and separate three things: the legal test, the facts used to apply that test, and any policy or institutional reason the court gave. This structure makes Fort Halifax Packing Co. v. Coyne easier to use in essays and problem questions. In Pension and Employee Benefits Law, the case should be compared with related authorities on ERISA - preemption; state plant closing law; severance pay; if the jurisdiction, statute, or procedural posture differs from the exam problem, explain that limit explicitly instead of treating the authority as automatic.

Plain-English Explanation

Plainly, Fort Halifax Packing Co. v. Coyne is a case to use when a Pension and Employee Benefits Law answer needs an authority on ERISA - preemption; state plant closing law; severance pay. Do not just list it. Explain the problem the court had to solve, the rule or holding it used, and the fact that made the result persuasive. That turns the case from a memorised name into evidence for your legal analysis.

Essay-Ready Explanation Generator

Version 1 of 4

Reference to Fort Halifax Packing Co. v. Coyne (482 U.S. 1) strengthens a Pension and Employee Benefits Law answer because the case reflects the principle that A state law that imposes a single, uncomplicated obligation (like a lump-sum severance payment upon plant closing) does not 'relate to' an ERISA plan and is not preempted, because it does not require the creation of an ongoing administrative plan. Applied to a problem question, the case should be used after identifying the issue as Whether a state law requiring a one-time severance payment upon plant closing is preempted by ERISA. The stronger essay move is to connect the material facts to the court's holding, then explain whether the present facts support the same conclusion or justify distinguishing the authority.

Underlying Concepts

  • pension-and-employee-benefits-law
  • Pension and Employee Benefits Law
  • ERISA - preemption; state plant closing law; severance pay
  • case authority
  • exam application

Key Passages

  • Verify exact wording in the linked source before quoting.

Significance

Fort Halifax Packing Co. v. Coyne is significant for LawConquer users because it supplies a named authority for ERISA - preemption; state plant closing law; severance pay in Pension and Employee Benefits Law. The case can anchor a paragraph, support a rule statement, or provide a contrast point when another authority points the other way. Its practical value is strongest when the student links the holding to the material facts and then explains whether the present problem is analogous or distinguishable.

Related Cases

No related cases listed.

Exam Tips

In an exam, introduce Fort Halifax Packing Co. v. Coyne with the citation only if you can remember it accurately; otherwise use the case name and court, then focus on the rule and application. A strong answer should say what Fort Halifax Packing Co. v. Coyne decided, why the facts mattered, and how the authority helps resolve the new facts. Avoid treating the case as a decorative reference. Use it to prove a doctrinal step in ERISA - preemption; state plant closing law; severance pay, then move quickly to analysis.

Revision Checklist

  • Name the issue before discussing facts so the marker sees the legal question immediately.
  • State the holding in one sentence, then use the ratio to explain why the court reached that result.
  • Use the citation and jurisdiction to show why this authority matters for the problem you are answering.
  • Pair this case with one supporting or contrasting authority if the question tests limits, policy, or exceptions.

Problem Question Use

Use Fort Halifax Packing Co. v. Coyne in a problem question by matching the factual trigger to the new scenario. If the fact pattern aligns with Maine law required employers to provide a one-time severance payment to employees upon a plant closing., apply the ratio and explain the likely result. If a crucial fact, jurisdiction, statute, or procedural posture differs, distinguish the case and use it as a boundary rather than a controlling answer.

Common Pitfalls

  • Name-dropping the case without applying the facts
  • Ignoring jurisdiction or procedural posture
  • Quoting without checking the linked source

Sources