Simas v. Quaker Fabric Corp.: ERISA Preemption of Statutory Tin Parachutes

Authors

Kristin D. Anger

Abstract

In Simas v. Quaker Fabric Corp., the First Circuit invalidated Massachusetts's innovative tin parachute statute, designed to assist workers displaced by corporate takeovers, by finding it preempted by ERISA. After examining the relationship between the tin parachute and ERISA and the analysis in Simas, this Note argues that preemption was mandated neither by ERISA itself nor by decisions interpreting its preemptive reach. In light of the state interest at stake, the Simas decision is unfortunate and suggests the need for a legislative solution.

First Page

1049

Recommended Citation

Kristin D. Anger, Notes and Comments, Simas v. Quaker Fabric Corp.: ERISA Preemption of Statutory Tin Parachutes, 69 Wash. L. Rev. 1049 (1994).
Available at: https://digitalcommons.law.uw.edu/wlr/vol69/iss4/4