alessi argued march decided may two suits initiated new jersey state retired employees received workers compensation awards subsequent retirement challenged validity provisions employers pension plans reducing retiree pension benefits amount equal workers compensation award retiree eligible private pension plans subject federal regulation employee retirement income security act erisa employers independently removed suits federal district judges suit held pension offset provisions invalid provision new jersey workers compensation act prohibiting offsets congress intended erisa state laws offsets prohibited erisa provision prohibiting forfeitures pension rights except specified conditions inapplicable cases treasury regulation authorizing offsets based workers compensation awards invalid appeals consolidated appeals two decisions reversed held congress contemplated approved kind pension provisions challenged pp pension plan provisions offsets based workers compensation awards contravene erisa nonforfeiture provisions prohibits forfeitures vested rights specified exceptions include workers compensation offsets nevertheless provisions make clear erisa leaves private parties creating pension plan determination content amount benefits vested forfeited statutory definition nonforfeitable pension benefits assures employee claim protected benefit legally enforceable guarantee particular amount method calculating benefit cf nachman pension benefit guaranty particularly pertinent congress prohibit integration calculation practice benefit levels determined combining pension funds public income streams available retired employee rather congress accepted practice expressly preserving option pension fund integration benefits available social security act railroad retirement act offsets pension benefits workers compensation awards work much like integration pension benefits social security railroad retirement payments thus nonforfeiture provision applicability former kind integration latter pp although neither erisa legislative history mentions integration workers compensation erisa forbid treasury regulation permitting reductions pension benefits based awards state workers compensation laws internal revenue service rulings effect merit argument integration pension funds workers compensation awards based injuries lacks rationale behind erisa permission integration pension funds social security railroad retirement payments supply payments wages lost due retirement social security railroad retirement acts also provide payments disability erisa permits pension integration benefits well benefits wages lost due retirement moreover enacted erisa congress knew irs rulings permitting integration workers compensation benefits left effect pp new jersey statute question federal law insofar eliminates method calculating pension benefits plans governed erisa provision erisa stating act provisions shall supersede state laws relate covered employee benefit plan demonstrates congress meant establish pension plan regulation exclusively federal concern regardless whether purpose new jersey statute might protect employee right workers compensation disability benefits rather regulate pension plans statute relate pension plans governed erisa eliminates one method calculating pension benefits integration permitted federal law state provision thus impermissible intrusion federal regulatory scheme moment new jersey intrudes indirectly workers compensation law rather directly statute called pension regulation since erisa makes clear even indirect state action bearing private pensions may encroach upon area exclusive federal concern moreover pension plans emerge collective bargaining additional federal interest precluding state interference negotiations calls state efforts regulate pension terms pp marshall delivered opinion members joined except brennan took part decision cases together buczynski et al general motors et certiorari theodore sachs argued cause appellants briefs michael scarola mark steckloff marc gettis argued cause filed briefs petitioners warren john casey argued cause appellees brief sebastian fortunato laurence reich argued cause respondent brief otis smith eugene hartwig david davis john degan attorney general stephen skillman assistant attorney general michael bokar deputy attorney general filed brief state new jersey appellee rule respondent rule fn briefs amici curiae urging reversal filed alfred miller american association retired persons et al gill deford neal dudovitz gray panthers leonard zubrensky theodore sachs merl stong et al briefs amici curiae urging affirmance filed solicitor general mccree acting assistant attorney general murray stuart smith william friedlander michael roach richard wentley patrick ritchey industries stanley kaleczyc chamber commerce george pantos erisa industry committee charles volk william scott national steel justice marshall delivered opinion private pension plans reduce retiree pension benefits amount workers compensation awards received subsequent retirement cases consider whether two offset provisions lawful employee retirement income security act erisa stat amended et seq ed supp iii whether may prohibited state law general motors maintain employee pension plans subject federal regulation erisa plans provide employee retirement benefits shall reduced offset amount equal workers compensation awards individual eligible new jersey legislature amended workers compensation act expressly prohibit offsets amendment right compensation granted chapter may set disability pension benefits payments shall set employees retirement pension benefits payments stat ann west supp amended laws ch alleging violations provision state law two suits initiated new jersey state plaintiffs suits retired employees obtained workers compensation awards subject offsets retirement benefits pension plans defendant companies independently removed suits district district new jersey district judges ruled pension offset provisions invalid new jersey law concluded congress intended erisa state laws sort district judges also held offsets prohibited erisa section prohibits forfeitures vested pension rights except four specific conditions inapplicable cases judges concluded offsets based workers compensation awards forbidden forfeitures struck contrary federal treasury regulation authorizing offsets appeals third circuit consolidated appeals two decisions reversed rejected district judges view offset provisions caused forfeiture vested pension rights forbidden instead appeals reasoned offsets merely reduce pension benefits fashion expressly approved erisa employees receiving social security benefits accordingly appeals found conflict erisa treasury regulation approving reductions based workers compensation awards erisa finally concluded new jersey statute forbidding offsets pension benefits amount workers compensation awards withstand erisa general provision noted probable jurisdiction appeal taken former employees granted certiorari petition former employees general motors convenience refer former employees cases retirees affirm judgment appeals ii retirees claim workers compensation offset provisions pension plans contravene erisa nonforfeiture provisions treasury regulation contrary inconsistent act claims require examination relevant sections erisa recently observed erisa comprehensive reticulated statute congress adopted careful study private retirement pension plans nachman pension benefit guaranty nachman observed congress erisa wanted ensure worker promised defined pension benefit upon retirement fulfilled whatever conditions required obtain vested benefit actually receives reason concepts vested rights nonforfeitable rights critical erisa scheme see erisa prescribes vesting accrual schedules assuring employees obtain rights least portions normal pension benefits even leave positions prior retirement critically erisa establishes ach pension plan shall provide employee right normal retirement benefit nonforfeitable upon attainment normal retirement age retirees rely sweeping assurance pension rights become nonforfeitable claiming offsetting benefits workers compensation awards violates erisa retirees argue first vested benefits may forfeited except expressly provided second retirees assert offsets based workers compensation fall none express exceptions claims correct prohibits forfeitures vested rights except expressly provided challenged workers compensation offsets among permitted section despite facial accuracy retirees argument overlooks threshold issue defines content benefit vested forfeited erisa leaves question largely private parties creating plan private parties government control level benefits clear statutory language defining nonforfeitable rights well portions erisa erisa defines nonforfeitable pension benefit right claim obtained participant beneficiary part immediate deferred benefit pension plan arises participant service unconditional legally enforceable plan construing definition last term observed term forfeiture normally connotes total loss consequence event rather limit value person rights examples plan provision expressly described causing forfeiture listed describes event death temporary might otherwise construed causing forfeiture entire benefit therefore surely consistent statutory definition nonforfeitable view describing quality participant right pension rather limit amount may collect nachman pension benefit guaranty rather imposing mandatory pension levels methods calculating benefits congress erisa set outer bounds permissible accrual practices specified three alternative schedules vesting pension rights congress limited variation permitted accrual rates applicable across entire period employee participation pension plan congress disapproved pension practices unduly delaying employee acquisition right enforce payment portion benefits already accrued without employment provisions together assure minimum legally enforceable claim pension benefits created covered plan employees completed years service employees aged older completed years service restrictions erisa permits total benefit levels formulas determining accrual completion years service vary plan plan see benefits defined merely plan particularly pertinent purposes congress prohibit integration calculation practice benefit levels determined combining pension funds income streams available retired employees integration income stream contributes calculation purposes total benefit pool distributed retired employees even nonpension funds available subgroup employees pension funds thus integrated funds income maintenance programs social security pension benefit level determined basis entire pool funds practice individual employee eligibility social security advantage participants private pension plan addition anticipated social security payments total benefit pool permit higher average pension payout participant employees group profit higher pension level although individual employee may reach level combination payments pension fund payments income maintenance source addition integration allows employer attain selected pension level drawing resources like social security also depend employer contributions following extensive study private pension plans adoption erisa congress expressly preserved option pension fund integration benefits available social security act et seq ed supp iii railroad retirement act et seq ed supp iii iv congress well aware pooling nonpension retirement benefits pension funds limit total income maintenance payments received individual employees reduce cost pension plans employers indeed considering integration option house ways means committee expressly acknowledged tension primary goal benefiting employees subsidiary goal containing pension costs committee report noted proposed bill affect ability plans use integration procedures reduce benefits pay individuals currently covered social security benefits liberalized committee however believes practices raise important issues one hand objective congress increasing social security benefits might considered frustrated extent individuals low moderate incomes private retirement benefits reduced result integration procedures hand committee much aware many present plans fully partly integrated elimination integration procedures substantially increase cost financing private plans employees whole might injured rather aided cost increases resulted slowing growth perhaps even eliminat ing private retirement plans reprinted legislative history employee retirement income security act committee print compiled senate committee labor public welfare leg setting limitation integration social security railroad retirement benefits congress acknowledged accepted practice rather prohibiting moreover permitting integration least federal benefits congress find necessary add exemption purpose stringent nonforfeiture protections circumstances unpersuaded retirees claim nonforfeiture provisions force prohibit offset pension benefits workers compensation awards offsets work much like integration pension benefits social security railroad retirement payments individual employee remains entitled established pension level payments received pension fund reduced amount received workers compensation nonforfeiture provision applicability kind integration analogous reduction permitted social security railroad retirement payments indeed congressional purpose promoting system private pensions giving employers avenues cutting cost pension obligations underlies offset possibilities nonetheless erisa mention integration workers compensation legislative history equally silent point argument advanced congress approved integration pension funds federal benefits expressly mentioned act current regulation issued internal revenue service however goes permits integration benefits provided federal state law must consider whether regulation consistent erisa codified cfr treasury regulation provides nonforfeitable rights considered forfeitable reason fact may reduced take account benefits provided social security act federal state law taken account determining plan benefits regulation interprets section internal revenue code replicates irs purposes erisa nonforfeiture provision regulation plainly encompasses awards state workers compensation laws addition revenue rulings issued prior erisa irs expressly approved reductions pension benefits corresponding workers compensation awards see rev rul part cum bull rev rul cum bull retirees contend treasury regulation irs rulings effect contravene erisa object first erisa approval integration limited social security railroad retirement payments objection precluded conclusion reduction pension benefits based integration procedure per se prohibited level pension benefits prescribed erisa retirees remaining objection workers compensation awards different kind social security railroad retirement payments integration authorized rubric developing argument retirees claim workers compensation provides payments injuries social security railroad retirement supply payments solely wages lost due retirement distinction retirees conclude integration pension funds workers compensation awards lacks rationale behind integration pension funds social security railroad retirement retirees claim presumes erisa permits integration social security railroad retirement identity purposes pension payments purposes integrated benefits even funds congress clearly approved integration purposes share identity purpose ascribed petitioners social security railroad retirement acts provide payments disability well wages lost due retirement erisa permits pension integration without distinguishing different kinds benefits furthermore enacted erisa congress knew irs rulings permitting integration left effect rulings draw line permissible impermissible integration retirees prefer instead include workers compensation offsets within ambit permissible integration irs rulings base allowance pension payment integration three factors employer must contribute benefit funds funds must designed general public use benefits supply must correspond benefits available pension plan irs employed considerations approving integration workers compensation benefits rev rul part cum bull rev rul cum bull contrast irs disallowed offsets pension benefits damages recovered employee action employer rev rul part cum bull rev rul cum bull irs also permitted integration reimbursement medical expenses fixed sums made bodily impairment payments match benefits available pension plan qualified internal revenue code erisa rev rul cum bull similarly irs disapproved integration unemployment compensation payment temporary layoffs kind benefit comparable permitted qualified pension plan without speaking directly rationale congress embraced irs rulings see conf leg hist approving existing antidiscrimination rules congress thereby permitted integration along lines already approved irs specifically allowed pension benefit offsets based workers compensation judicial function policy decisions legislature matter appealing may find contrary rationales final argument retirees claim defer policy decisions state legislature claim turn iii new jersey legislature attempted outlaw offset clauses providing right compensation granted new jersey workers compensation act may set disability pension benefits payments shall set employees retirement pension benefits payments stat ann west supp emphasis added resolve retirees claim state policy govern must determine whether state laws erisa analysis problem must guided respect separate spheres governmental authority preserved federalist system although supremacy clause invalidates state laws interfere contrary laws congress gibbons ogden wheat exercise federal supremacy lightly presumed new york dept social services dublino quoting schwartz texas recently reiterated reemption state law federal statute regulation favored absence persuasive reasons either nature regulated subject matter permits conclusion congress unmistakably ordained chicago north western transp kalo brick tile quoting florida lime avocado growers paul see jones rath packing perez campbell rice santa fe elevator hines davidowitz instance assisted explicit congressional statement effect action chapter erisa defines scope federal protection employee pension benefits provides provisions subchapter shall supersede state laws insofar may hereafter relate employee benefit plan described section title exempt section title agree conclusion reached appeals arrive different route whatever purpose purposes new jersey statute conclude relate pension plans governed erisa eliminates one method calculating pension benefits integration permitted federal law erisa permits integration pension funds public income maintenance moneys purpose calculating benefits irs interpretation approves integration exact funds addressed new jersey workers compensation law new jersey effort ban pension benefit offsets based workers compensation applies directly calculation technique need determine outer bounds erisa language find new jersey provision impermissible intrusion federal regulatory scheme moment new jersey intrudes indirectly workers compensation law rather directly statute called pension regulation erisa makes clear even indirect state action bearing private pensions may encroach upon area exclusive federal concern purposes provision erisa defines term state include state political subdivision thereof agency instrumentality either purports regulate directly indirectly terms conditions employee benefit plans covered subchapter emphasis added erisa authors clearly meant preclude avoiding form substance preemption provision another consideration bolsters conclusion new jersey provision insofar bears pensions regulated erisa erisa leaves integration along pension calculation techniques subject discretion pension plan designers see supra pension plans emerge collective bargaining additional federal interest precluding state interference negotiations calls state efforts regulate pension terms see teamsters oliver railway employees hanson cf motor coach employees lockridge san diego building trades council garmon subject collective bargaining pension terms become expressions federal law requiring intrusive state law iv conclude stat ann west supp federal law insofar bears pension plans governed erisa find congress contemplated approved kind pension provisions challenged permit offsets pension benefits based workers compensation awards decision appeals affirmed footnotes retirement income payments shall reduced entire amount payments member eligible receive statutes pertaining workmen compensation occupational disease unemployment compensation cash sickness benefits similar laws primary social security benefits presently effect may enacted time time payments paid concurrently retirement income determining monthly benefits payable plan deduction shall made unless prohibited law equivalent part workmen compensation including compromise redemption settlements payable employee reason law political subdivision thereof shall enacted provided deductions shall extent workmen compensation provided premiums taxes payments paid expense corporation except deduction shall made following workmen compensation payments specifically allocated hospitalization medical expense fixed statutory payments loss bodily member loss use bodily member payments loss industrial vision compromise redemption settlements payable prior date monthly pension benefits first become payable workmen compensation payments paid claim filed later two years breaking seniority former employees sought permanently enjoin offsets recover damages offsets already made similar relief pursued several former employees general motors brought suit behalf others similarly situated see infra regulation provides nonforfeitable rights considered forfeitable reason fact may reduced take account benefits provided social security act federal state law taken account determining plan benefits cfr statement findings declaration policy congress noted despite enormous growth plans many employees long years employment losing anticipated retirement benefits owing lack vesting provisions plans erisa designed prescribe minimum vesting accrual standards response problems ibid ensure employee pension expectations defeated act establishes minimum rules employee participation funding standards increase solvency pension plans fiduciary standards plan managers insurance program case plan termination ed supp iii erisa establishes three accrual techniques pension plans covered act see infra similarly erisa establishes several approved vesting schedules approved schedules time prior normal retirement age given period service combination age length service employee guaranteed interest pension benefit see infra erisa defines normal retirement benefit greater early retirement benefit plan benefit plan commencing normal retirement age statute expressly exempts forfeiture ban offsets contingent employee death occur employee takes job certain circumstances due certain retroactive amendments pension plan result withdrawals benefits derived mandatory contributions retirees correctly point workers compensation offsets fall none categories three different accrual practices approved defined benefits plans described one prescribes minimum percentage total retirement benefit must accrued given year another permits use accrual formula long accrual rate given year service vary beyond specified percentage accrual rate year plan third essentially pro rata rule given year employee accrued benefit proportionate number years service compared number total years service appropriate normal retirement age congress approved delay employee acquisition vested right portions pension derived employer contributions thus erisa specifies right hinged minimum length service employee reaching minimum lose right even continue working particular employer reaching retirement age minimum period service calculated three different formulas two permit gradual vesting percentages accrued benefits time compare see also schiller proposed erisa vesting regulations seem discussing internal revenue service implementation vesting provisions essence pension plans qualifying tax treatment advantageous employer must ensure nonforfeiture accrued benefits derived employee contributions must use vesting accrual rates assuring portions benefits derived employer contributions employee leave job normal retirement age minimum results formulas approving gradual vesting time benefits derived employer contributions see alternatively plan may comply erisa employee least years service nonforfeitable right percent accrued benefit derived employer contributions vesting nonforfeiture pension benefits provisions bill discussed substantially identical portions bill ultimately enacted erisa bill reported conference committee included additional provision restrict temporarily increases pension reductions due increases social security benefits occurring december conf leg hist senator harrison williams explained provision ultimately deleted told greatly increase costs private pension plans something sure none senators like see occur particularly true increased pension costs result termination private pension plans certainly intent legislation designed improve encourage expansion private pension plans cong rec leg hist appeals characterized treasury regulation legislative regulation entitled restricted scope review applied interpretive rules nonetheless government represents treasury regulation interpretive rule brief amicus curiae agency empowered enact legislative rules may choose issue nonlegislative statements review treasury regulation scrutiny applicable interpretive rules due deference consistent agency practice see batterton francis batterton marshall app davis administrative law treatise ed furthermore integration workers compensation approved agency created erisa guarantee payment nonforfeitable pension benefits despite termination relevant pension plan agency pension benefit guaranty corporation defined benefits guarantees include benefit payable annuity one payments related thereto participant permanently leaves permanently left covered employment surviving beneficiary payments combination social security railroad retirement workmen compensation benefits provide substantially level income recipient cfr house ways means committee report proposed codification contemporaneous administrative practice developed irs practice included irs approval integration procedures see cfr rev rul part cum bull rev rul cum bull irs rulings implemented provision internal revenue code forbids favorable tax treatment pension plans discriminating favor company officers shareholders highly compensated employees internal revenue code long enactment erisa specified forbidden discrimination include differences benefits retirement benefits created state federal law supp iii irs consistently interpreted discrimination provision permit pension benefit integration social security funds receiving employer contributions making benefits available general public see rev rul cum bull rev rul cum bull rev rul cum bull rev rul cum bull congress essentially approved rulings conference committee reported conferees intend antidiscrimination rules present law areas vesting schedule changed thus present antidiscrimination rules respect coverage respect contributions benefits remain effect conf leg hist retirees argue workers compensation treated tort damages purposes integration pension payments although workers compensation resembles tort judgments employers employee injuries differences explain different treatment irs tort judgment typically represents finding employer fault employee injury workers compensation contrast generally available showing employer fault employee lack fault injury larson workmen compensation law treating two sources payments differently irs may concluded workers compensation much income maintenance program responding wage loss remuneration injury therefore may integrated pension benefits advantage entire employee group see generally cf richardson belcher reductions social security based workers compensation comports due process light agency may well employed rationale proffered retirees two benefits systems must identical purposes may integrated departed retirees reasoning concluding two benefit systems share purpose replacing lost wages whatever cause regardless view workers compensation finds compelling must defer consistent agency position reasonable consonant act note general motors offset clause avoids ambiguity point disallows deductions medical expenses fixed payments bodily impairment see supra although plan silent point certainly subject irs regulation adopted amendment new jersey workers compensation act provision reversed new jersey prior approval workers compensation offsets collectively bargained pension agreements see brief appellee new jersey pp scope federal concern however limited erisa statute explicitly preserves state regulation insurance banking securities generally applicable criminal law state erisa also exempts coverage several kinds plans may subject state regulation see also conf leg hist erisa clause exempts state laws relating pension plans fall within act coverage see supra exemptions applicable exemption conceivable relevance pertains state laws governing plans maintained solely purpose complying applicable workmen compensation laws retirees concede exception inapplicable general motors plan maintained solely comply workmen compensation law brief petitioners retirees however claim exception apply generally plans governed state workers compensation laws reason plan designed comply applicable workmen compensation law preempted erisa fortiori underlying statute plan permitted comply equally escapes coverage reply brief appellants reasoning wreaks havoc erisa plain language plans state laws relevant state laws portions thereof survive provision relating plans exempted erisa scope relevant exemption erisa coverage plans maintained solely compliance state workers compensation laws bearing plans involved broadly serve employee needs result collective bargaining retirees claim plans involved free erisa coverage claim exception restricted laws governing exempted plans courts reached varying conclusions meaning erisa language contexts see american telephone telegraph merry stone stone supp nd cal gast state app express views merits decisions light reading erisa appeals declined reach issue national labor relations act issue however addressed district alessi civ nj reasoned federal labor law extend far preclude state regulation conduct touching deeply rooted local concerns ibid citing san diego building trades council garmon although reasoning may apply contexts find compelling light direct clash state statute federal policy keep calculation pension benefits subject either negotiations federal legislation context integration pension benefits public income maintenance funds forbidden terms pension plans new federal legislation conclusion follows naturally view plurality malone white motor congress preserved state role pension regulation erisa plurality created exception general rule state regulation collective bargaining exception longer applies however erisa express intent eliminated state regulation pension plans