An amicus brief (amicus curiae, “friend of the court”) is a legal brief submitted by a non‑party to a case to provide information, expertise, or legal arguments that may assist the court; typical filers include advocacy groups, industry associations, academics, state or federal agencies, and other interested organizations or individuals.
Title I of ERISA sets federal rules for private-sector employee benefit plans — including reporting and disclosure, participation and vesting, fiduciary conduct, funding, and civil enforcement — and its administration and enforcement authority is assigned primarily to the Department of Labor’s Employee Benefits Security Administration (EBSA).
Forfeited employer contributions are the unvested portion of employer contributions that revert to the plan when an employee leaves before those contributions vest; plan rules and tax/ERISA regulations generally require forfeitures be used to pay plan expenses or to fund/reduce future employer contributions (subject to plan terms and law).
A plan that grants fiduciary discretion over forfeiture allocation gives the plan fiduciary (as defined under ERISA) the authority under the plan document to decide how forfeitures are applied (for example, to pay plan expenses or offset employer contributions) within the limits of ERISA fiduciary duties.
The Third Circuit is the U.S. Court of Appeals for the Third Circuit (an intermediate federal appellate court covering parts of the Mid‑Atlantic); for it to “affirm” a lower court decision means the appeals court agrees with and upholds the lower (district) court’s ruling, leaving that judgment in place.
Barragan v. Honeywell Int’l Inc. is a lawsuit by a plan participant (plaintiff Barragan) against Honeywell (the plan sponsor) alleging ERISA fiduciary‑breach claims tied to how forfeitures were used; the plaintiff alleged the sponsor misallocated forfeitures but the district court dismissed the claims (the DOL’s amicus brief asks the Third Circuit to affirm that dismissal).
In Wright v. JPMorgan Chase & Co. and Hutchins v. HP Inc., federal district courts dismissed similar ERISA claims challenging use/allocation of forfeitures; the DOL cites those dismissals to show prior courts have rejected bare‑pleading forfeiture claims where plan language gives fiduciaries discretion or the complaint lacks factual detail. (Those cases were used as illustrative precedent in the DOL brief.)