F. Schumacher & Co. v. Alvord-Polk, Inc.

How later courts describe this case

• applying Graham v. Connor, 490 U.S. 386, 109 S.Ct. 1865, 104 L.Ed.2d 443 (1989)
• noting the lack of any precedent granting a non-party’s motion for joinder
• “ERISA section 206(d)(1) protects ERISA-qualified benefits from garnishment only until paid to and received by plan participants or beneficiaries.”
• statements made by trade association's officers, including the president, published in the association's newsletters were adoptive admissions of the association, even though there was a general disclaimed printed at the beginning of the newsletter.
• ERISA does not protect funds once benefits are paid and received